General Tax Considerations in Cross-Border Investing (continued) • Maintain VCOC status• Wil a buyer like the structure or be able to restructure on a tax efficient basis? Foreign Mirror Fund to Mitigate CFC Consequences (Investments in CFCs made through mirror foreign partnership(s)) • Cayman Fund not a U.S.
CFC Planning Techniques – CTB Elections (continued) • A single-member entity which elects to be flow through for U.S.
Check the Box Elections to Avoid Subpart F Income LPs GPs • DRE 1 and DRE 2 treated as branches of CFC • Interest dividends and service fees (all potentially Subpart F income) Delawar eliminated for U.S. CFC Planning Techniques – Earnings Reduction (continued) • Section 338 Election – If a CFC wil be paying material non-U.S.
Elections to Ameliorate PFIC Consequences • Qualified Electing Fund (“QEF”) Election – U.S. Elections to Ameliorate PFIC Consequences (continued) • Mark-to-Market Election – Rarely available for private equity investments– U.S. Qualified Dividends (continued) • LOB – Difficult for funds with investors from multiple countries • Dividends for this purpose include amounts deemed to be dividends under Section 1248 (from the sale of a CFC) • Dividends from a PFIC are never qualified• Section 1248 gain treated as dividends which may be qualified • Provision sunsets December 31, 2010 – any possibility of extension? Avoiding Phantom Income Hybrid Instruments and Entities • Loans to disregarded entities• Hybrid instruments – treated as debt in country of issuance but equity for U.S. Loan to Disregarded Entity • Interest on shareholder loan deductible in Bidco’s Country PE Fund • Shareholder loan (and interest thereon) ignored in U.S. Luxembourg Structure (continued) – Interest on shareholder debt deductible on accrual basis in group. Primary UBTI Concerns in Private Equity Transactions • Investments in flow-through vehicles• Leveraging investments• Guaranteeing portfolio company debt – Who is the true borrower?
Definition Of Operating Company • An entity primarily engaged, directly or through its majority-owned subsidiary or subsidiaries in the production or sale of a product or service other than the investment of capital. Strategic Financial Planners is an independent financialA services firm and does not provide any proprietary products.
A family limited partnership could help business owners and their heirs address business succession and other issues. Global oil price instability may have consequences for corporate profits and national economies. According to a recent report, homeowners who filed just one insurance claim saw their premiums rise by an average of 9%. Knowing your likely life expectancy is an important factor in making long-term financial plans. Compare the potential future value of tax-deferred investments to that of taxable investments. Slideshare uses cookies to improve functionality and performance, and to provide you with relevant advertising.
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We’re one team united behind a common purpose, growing together to build a better future for our clients, community and each other. Founded in 1979, Strategic Financial Services is an independent wealth management firm specializing in investment management, financial planning, and company sponsored retirement plans. Our work focuses on education, goal setting and discipline with an eye on institutional advancement. We view each relationship as a partnership and take pride in serving as an advocate in the community for our client’s overall mission. We manage retirement plans that are uniquely tailored to your organization, and all its stakeholders.
Third party rankings and recognition from ratings services are no guarantee of future investment success.
2 The assets included in this calculation includes assets of advisory client accounts, retail client accounts, and monitored client accounts. Difference between strategic and financial planning is that financial planning is about planning for the finances or use of cash flows over a period of time while strategic planning is about planning the road-map of the organization. In most of the organizations, there is a separate finance department in order to plan for the financial activities. In the modern competitive business environment, it is very much essential to create a strategic plan for the survival of the business organization. Strategic planning can be considered as a step by step process as stated in the below diagram. The first step is to develop the strategic vision which defines the ultimate goal of the organization. Strategic planning can be identified as an organizational management activity that is used to set priorities, focus on energy and resources, ensure that employees and other stakeholders are working towards common goals, strengthen the operations, get the expected results. If you interesting in "Private Equity Strategic Financial Management Conference" powerpoint themes, you can download to use this powerpoint template for your own presentation template. Lemanowicz, Dechert LLP – PhiladelphiaRyan Davis, KPMG LLP – London 11709159 M aterials have been abridged from  law s, court decisions, and adm inistrative rulings and should not be considered as legal opinions on specific facts or as a substitute for legal counsel. Delaware Fund will include Delawar in gross income its share of such e Fund income, and U.S. Shareholders of a CFC – Subsidiaries • Look-through 25% owned subsidiaries and income in testing PFIC status • What about gain on sales of 25% owned subsidiary?
Therefore, we have the ability to provide the best investment productsA in the industry to help our clients reach their goals and objectives.A  You can be assured that any advice or recommendations are given completely in an unbiased nature.
From Strategies for growth, to contingency planning and asset protection, our responsibility is to empower clients in the pursuit of their financial goals.
From your executive office to the shop floor, we provide customized investment management, consulting, education and advice. Working with a highly rated adviser does not ensure that a client or prospective client will experience a higher level of performance or results.
Advisory client accounts are accounts that Strategic provide continuous and ongoing management services.


The finance department is responsible for preparing financial statements such as the income statement, balance sheet and cash flow statement at the end of a specific period. The main purpose of strategic planning is to establish the direction or vision for the organization and then the resources need to be aligned with the goals of the company. It is kind of a collaborative effort of all the employees within the organization and therefore success depends on their contribution towards achieving the goals of the organization. For viewing only, you can play with our flash based presentation viewer instead of downloading the ppt file.
Shareholders must include in income their share of the CFC’s increase in earnings invested in U.S.
We seek to develop and maintain long term relationships with the people and families that we work with. The profile helps you formulate strategies that augment your business by enabling you to understand your partners, customers and competitors better. Retail accounts are accounts where an advisory representative serves as registered rep on the account and provides advice on an intermittent basis. Then, strategic planning is setting the plans for the future considering the vision and mission of the company. A financial plan is created in order to achieve the financial objectives of the organization. Then, the next step is to crafting a strategy in order to achieve the stated objectives and vision and then implement the strategy. LPs who own indirectly 10% of CFC subject to CFC rules (rarely an issue in larger funds) • U.S. This company report forms part of the ‘Profile on Demand’ service, covering over 50,000 of the world’s leading companies. Monitored client accounts are accounts that Strategic monitors and may provide investment and planning recommendations, but does not have trading authority over.
Normally budgets are prepared with compared to the previous years’ company performances.
After that monitoring is required in order to evaluate the performance and make the necessary adjustments. GP and carried interest – might have CFC consequences GPs • LPA must indicate how profits and losses offset for purposes of carry >10% • ERISA Consideration: Is Cayman Fund Delawar Cayman a VCOC?
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Nothing on this web site shall be considered a solicitation to buy or an offer to sell a security to any person in any jurisdiction where such an offer, solicitation, purchase or sale would be unlawful under the securities laws of such jurisdiction.



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