The Investments Lawyer (Michael Huseby) Profile picture
Investment funds + securities lawyer. Managing Member at https://t.co/lvzUKYCRTT. Ex @lathamwatkins / @DLA_Piper. Newsletter on funds and SPVs: https://t.co/IJHSIc5hEN

Feb 21, 13 tweets

What you need to do if you want to accept money from:
💰 Tax-exempt investors
🌍 Non-US investors

A big post discussing UBTI, ECI, blockers, and more.

⚠️ This is especially true for real estate and private equity (but is sometimes relevant for venture capital...we've seen it before).

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Tax-exempt investors and UBTI

Where does UBTI come from?

How do funds generate UBTI?

Mitigating UBTI concerns

How to handle UBTI concerns with tax-exempt LPs

Non-US investors and ECI

How passive and active income are taxed

What's so bad about ECI?

The terrors of FIRPTA

How funds generate ECI

How to mitigate ECI concerns

How to handle ECI conversations with non-US LPs

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