Institute for International Research

2:00 Workshop A:

Maximize your fund's value by utilizing the most advantageous Tax, Legal, Regulatory and Valuation Methodologies

Attendees will analyze various GPs' and LPs' perspectives on the underlying issues affecting Funds of Funds' and their investors' operations. Participants will learn the best tactics to mitigate litigation risk, gain advantage of recent tax regulations and effectively apply reporting valuation guidelines.

Delegates then will be asked to analyze practical examples and work through hypothetical case studies to illustrate how these issues affect the structure, investment process, and returns of a fund of funds. Following the hypothetical case study, there will be plenty of time for Q&A and discussion of your own deals.

Delegates will leave the workshop with practical tools to:

• Effectively structure your fund operations based on Federal tax regulations and increasingly more aggressive approach by the states to tax collection
  
• Gain maximum tax advantage through hands-on analysis of domestic and foreign LPs tax withholding issues
  
• Mitigate the impact of FAS 157, Fair Value Measurements and recent trends when performing valuations or accounting activities
  
• Improve your accounting practices by understanding the impact of the AICPA's Interpretation of AU 332, Auditing Alternative Investments
  
• Manage FOIA and other disclosure requirements when structuring deals
  
• Learn how valuations are put together and how to effectively calculate fair market value for the underlying funds

Leaders:
Tina E. St. Pierre, Principal, LANDMARK PARTNERS
Timothy Grady, Assurance Partner, PWC LLP
Glen Stevenson, CPA, MST, Tax Dir., NAUTIC PARTNERS
Ajay Saini, CFO, GROVE STREET ADVISORS
Steven D. Bortnick, Partner, PEPPER HAMILTON LLP

2:00 Workshop B:

Increasing Profits by Expanding Overseas: Structuring offshore funds and international tax

Exploring opportunities abroad exposes for major funding and tax advantages, but structuring and maintaining your offshore funds requires a concrete understanding of international taxation and regulations.

Using a practical, hands-on approach, participants will walk through hypothetical case studies to identify requirements and obtain the skills to successfully establish offshore funds.

Leading Offshore Fund Formation and Structuring

• Choosing where to domicile your fund and fund management
  
• Managing U.S. tax sensitive investors with foreign investment target limitations
  
• Measures to reduce taxable presence risks in the US and other high-tax jurisdictions
  
• Reducing currency risk and choosing a denomination that benefits both sides of the partnership
  
• The "nuts and bolts" of maintaining and operating an offshore fund

Minimizing US and Foreign Taxes

• Harnessing the value of bi-lateral income tax treaties and avoiding unfavorable tax regimes
  
• Managing off-shore funds in tax favorable jurisdictions such as the Cayman and Jersey Islands
  
• Planning around anti-deferral tax regimes and minimizing phantom income risks
  
• Avoiding taxation as a corporation and choosing the most tax-favorable entity

Capitalizing on International Structural Opportunities

• Attracting a larger investor base using alternative and parallel investment vehicles
  
• Taking advantage of structures to facilitate regional or country specific investments (e.g., The Netherlands, Luxembourg, Mauritius, Cyprus, Spain and Singapore )
  
• Managing exit events and planning for tax efficient repatriation and exit transactions

Leaders:
Kathleen Hayes, CFO and Controller, AMCI CAPITAL
Arturo Requenez, Partner, MCDERMOTT, WILL AND EMORY