Direct Lending Funds: Five Structures to Mitigate Tax Burdens for Various Investor Types (Part Two of Two)

Fund managers must balance competing tax and regulatory concerns when structuring direct lending funds for the benefit of different classes of U.S. and non-U.S. investors. There is no one-size-fits-all solution, and to that end, a recent webinar hosted by Strafford CLE Webinars that featured Sadis & Goldberg partners Alex Gelinas, Steven Huttler and Daniel G. Viola discussed the advantages and disadvantages of several different structures used by managers for direct lending funds. This second article in a two-part series analyzes how different fund structures will affect the tax concerns of U.S. investors, U.S. tax-exempt investors and non‑U.S. investors. The first article provided the panelists’ thoughts on using closed-end, open-end and hybrid structures for direct lending funds, as well as on managing regulatory compliance concerns. For more on private credit, see “ACA Panel Examines Compliance Issues Faced by Credit Managers” (Nov. 15, 2018); and “Ropes & Gray Survey and Forum Consider Credit Fund Structures, Leverage, Conflicts of Interest and Challenging Environment (Part Two of Two)” (Jul. 26, 2018).

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