Logical Formulas is committed to providing you with the best advice in structuring your offshore and cross-border investments.  Here are areas where we have specialized knowledge:

I.              Key Structuring Concepts

1.    Tax-Exempt Investors and the Importance of Structuring to Avoid “Unrelated Business Taxable Income” (UBTI)

2.    Structural Tax Strategies Employed by Hedge Funds and Their Managers 

3.    Structural Tax Strategies Utilized by Private Equity Funds and Why their Strategies differ from Strategies Used by Hedge Funds

4.    Blocker Strategies

a.     Domestic Blockers
b.    Foreign Blocker – Above Fund
c.     Foreign Blocker – Below Fund

II            Managing Cross-border Cash Flows

1.    How Managing US Withholding Tax on Outbound Cross-Border Cash Flows Makes All the Difference in the World. -  How to Comply with the Requirements  of Financial Institution Withholding Tax Agents

2.    Consequences to U.S. Investment Partnerships with Foreign Investor-Partners  

3.    Understanding the US Taxation of Passive Foreign Investment Companies and Controlled Foreign Corporations and which Fund Investors Care 

4.    Key things to know about the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) -- U.S. Real Property Holding Company -- Gain Recognized by a Foreign Person on the disposition of a U.S. Real Property Interest 

5.    Offshore Fund Considerations of Real Estate Investment Trust (REIT) Positions 

6.    Planning with Cross-border Tax Treaties 

III.           Tax Accounting Considerations

1.    US taxation of Domestic Regulated Investment Companies (Mutual Funds)

IV.           Tax Legislation / Tax Audits

1.    Recent US Legislative Proposals to Tax Carried Interests of Fund Managers Currently at Ordinary Income Rates

2.    New IRS Audit Developments Affecting Offshore Funds

Jeff Lonsdale
Logical Formulas
4516 Lovers Lane #122
Dallas, TX 75225
(214) 769-3322

jeff@logicalformulas.com