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Key Takeaways.
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Hedge Fund.
Location and Market.
For U.S. tax-exempt investors, the major concern is unrelated business taxable income (UBTI). If the fund manager makes investments into operating partnerships, any distributive share of income allocated to its partners will be UBTI and may be subject to income tax. A special issue exists for a special type of tax-exempt investor called a charitable remainder trust (CRT) in which an allocation of UBTI may cause the CRT to have an excise tax imposed equal to the amount of such UBTI. If on the other hand, the fund manager makes investments structured as corporations, the venture capital fund will not create UBTI from any of its capital gains, dividends, or interest. However, if there is acquisition indebtedness, this can potentially cause unrelated debt financed income which will be subject to the UBTI rules. Acquisition indebtedness is when an investor borrows cash to fund its investments. Some fund managers may use a blocker type entity in order to block any UBTI allocated to its tax-exempt investors. The same blocker entity may also be used to block effectively connected income (ECI) allocated to offshore investors, which is discussed below. An investor may also create its own blocker to invest in the fund manager, but then the burden of additional administrative and compliance costs will fall on the investor directly. If the blocker entity is a U.S. corporation, it will be taxed on 100% of the operating income from the operating partnership. A foreign blocker will be taxed only to the extent of its ECI but may be subject to branch profits tax as well.
Understanding Venture Capital.
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