Scope. How private equity funds are legally built and taxed: the limited partnership chassis, the jurisdictions (Delaware, Cayman, Luxembourg, Guernsey/Jersey, Ireland, UK), parallel funds and feeders, alternative investment vehicles (AIVs), blocker corporations for tax-exempt and non-US investors, carried interest taxation, and management equity plans (MEPs) at the portfolio-company level.
What the study covers
- 1Why structure matters
- 2The basic chassis: the limited partnership
- 3Jurisdictions — what each one is for
- 4Parallel funds, feeders and AIVs
- 5Blockers, UBTI and ECI — the core tax engineering
- 6Carried interest taxation (summary)
- 7Management fee waivers and other GP economics
- 8Holding structures below the fund
- 9US regulatory structuring touchpoints
- 10GP-level structuring
- 11Common pitfalls
- 12How an expert thinks about it