The new Reserved Alternative Investment Fund (RAIF) structure unveiled by Luxembourg offers U.S. managers a flexible new option for marketing in the E.U. In addition, the structure allows U.S. managers to take advantage of certain tax benefits. Thus, the RAIF is a game changer for hedge fund managers and can also be a useful vehicle for real estate and private equity funds. At a recent presentation, the Association of the Luxembourg Fund Industry (ALFI) provided a comprehensive overview of the business, tax and regulatory ramifications of the RAIF. This second article in our two-part series explores opportunities presented by RAIFs for U.S. managers – including hedge fund, real estate and private equity managers – as well as tax considerations of the new fund structure. The first article
summarized the panel’s discussion of the Luxembourg funds landscape and the key features of RAIFs. For more on the marketing options presented by Luxembourg fund structures, see “Luxembourg Financial Regulator Issues Guidance on AIFMD Marketing and Reverse Solicitation
” (Sep. 3, 2015); and “How Can Hedge Fund Managers Use Luxembourg Funds to Access Investors and Investments in Europe, Asia and Latin America?
” (Jul. 12, 2012).