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Industry study 18 of 22 · Private Equity Research Companion

Legal, Tax and Fund Structuring

~7,000 words

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

  1. 1Why structure matters
  2. 2The basic chassis: the limited partnership
  3. 3Jurisdictions — what each one is for
  4. 4Parallel funds, feeders and AIVs
  5. 5Blockers, UBTI and ECI — the core tax engineering
  6. 6Carried interest taxation (summary)
  7. 7Management fee waivers and other GP economics
  8. 8Holding structures below the fund
  9. 9US regulatory structuring touchpoints
  10. 10GP-level structuring
  11. 11Common pitfalls
  12. 12How an expert thinks about it