Tax considerations are a key driver of private fund structuring. A panel at the recent FRA Private Investment Fund Tax Master Class discussed the importance of ensuring that the tax disclosures included in a fund’s private placement memoranda match the structure and strategy of the fund set forth in its governing documents and explored the types of tax issues that are usually addressed in domestic funds, offshore funds and hybrid situations. The program featured David Benz, formerly a partner at Crowe LLP, and James C. Cofer, partner at Seward & Kissel. This article highlights the most relevant points from the discussion. For more from FRA, see “Hot Tax Topics for Private Fund Investors and Managers” (Jan. 21, 2021).