Chair: Richard C. LaFalce, Morgan Lewis & Bockius LLP, Washington, DC
Non-US Investors in Private Funds.
This panel will discuss recent US tax developments that impact private funds that admit non-US investors and the practical implications for private funds. The panelists will address tax reporting and managing the downward attribution rules for controlled foreign corporations, the formation and structuring of corporate blockers, withholding tax issues and negotiating side letter provisions for non-US investors in the private fund context.
Moderator: Ryan Au, Sherman & Sterling, Washington, DC
Panelists: Jeffrey Tate, Arent Fox, Washington, DC; David Richardson, KPMG, New York, NY; Friedemann Thomma, Venable, San Francisco, CA
Overview of Collective Investment Trusts: Popular Alternative to Mutual Funds for Institutional Investors.
This panel will discuss collective investment trust structures used by institutional retirement investors as alternatives to mutual funds and other pooled investment vehicles. Topics will include their regulation, organization and operation, key similarities and differences between trusts and mutual funds, and other vehicles, investment-related tax law considerations, and recent market trends.
Moderator: Amy Snyder, The Vanguard Group Inc., Malvern, PA
Panelists: Charles M. Horn, Morgan Lewis & Bokius LLP, Washington, DC; Marcy Kempf, Cohen & Company, Milwaukee, WI; Laura Parello, PwC, New York, NY
The Latest in Drafting Investment Fund Agreements.
This panel will discuss carried interest waivers, management fee waivers, 1446(f) indemnities, and BBA provisions.
Moderator: Anthony Tuths, KPMG, New York, NY
Panelists: Jon P. Brose, Seward & Kissel LLP, New York, NY; Janicelynn Asamoto Park, Proskauer, New York, NY