Taxes and K-1s
Partnership tax, K-1s, withholding, and the tax questions investors ask.
Articles from the Syndicately blog on this topic.
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In-Kind Distributions of Shares: How the Tax Rules Work
Read article: In-Kind Distributions of Shares: How the Tax Rules WorkIn-kind distributions transfer actual shares to SPV investors instead of cash. Here is when that transfer is tax free and when it creates taxable…
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SPV Distributions After an IPO: Lockups and Payout Choices
Read article: SPV Distributions After an IPO: Lockups and Payout ChoicesWhen a portfolio company goes public, the SPV faces a lockup period, then a choice between distributing shares in kind or selling them and…
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What is a 409A Valuation?
Read article: What is a 409A Valuation?If you’re giving equity to employees or anyone else providing services to your company, the IRS wants you to know what that equity is…
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Carried Interest and the Three-Year Holding Rule
Read article: Carried Interest and the Three-Year Holding RuleSection 1061 requires a partnership to hold an asset more than three years before gain allocated to a carried interest gets long-term capital gains…
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Foreign Investor Withholding for US SPVs
Read article: Foreign Investor Withholding for US SPVsA sponsor’s checklist for FDAP and Section 1446 withholding on foreign SPV investors, including Form W-8BEN collection and a worked example of the numbers.
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Self-Directed IRAs, SPVs, and UBTI
Read article: Self-Directed IRAs, SPVs, and UBTIWhen a self-directed IRA investing in an SPV owes unrelated business taxable income, how debt financing creates a separate UDFI exposure, and how to…
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The Worthless Stock Deduction for SPV Investors
Read article: The Worthless Stock Deduction for SPV InvestorsHow the worthless stock deduction works when a portfolio company fails, when part of the loss can be an ordinary loss under Section 1244,…
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Blocker Corporations Explained for SPV Investors
Read article: Blocker Corporations Explained for SPV InvestorsA blocker corporation sits between an SPV and its portfolio company so tax-exempt and foreign investors avoid UBTI and effectively connected income, at the…
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Year-End Tax Checklist for SPV and Private Investors
Read article: Year-End Tax Checklist for SPV and Private InvestorsA year-end tax checklist for SPV and private investment holders: K-1 timing, the January estimated tax deadline, cost basis tracking, and worthless positions.
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Cayman Islands SPVs and Offshore Feeders Explained
Read article: Cayman Islands SPVs and Offshore Feeders ExplainedWhy fund managers use a Cayman SPV as a blocker for tax exempt and non-US investors, and how a master feeder structure keeps investor…