PT  - JOURNAL ARTICLE
AU  - David M. Neuenhaus
AU  - Francis J. Helverson
TI  - U.S. Tax Planning Considerations for Investments in Foreign Portfolio Companies
AID  - 10.3905/jpe.2004.450954
DP  - 2004 Nov 30
TA  - The Journal of Private Equity
PG  - 76--83
VI  - 8
IP  - 1
4099  - https://pm-research.com/content/8/1/76.short
4100  - https://pm-research.com/content/8/1/76.full
AB  - Foreign investment by U.S. funds is increasingly common. Foreign investment involves complex U.S. tax issues that differ from those encountered in the purely domestic context. This article provides a road map to help advisors and fund professionals better understand a number of the important considerations. The article is not written in technical “tax speak,” and is intended to be accessible to readers with a non-tax background. It provides an overview of the tax considerations involved in making and holding foreign portfolio investments, a description of the tax treatment of the various participants, and then applies the concepts to three simplified common investment structures.