| Sovereign wealth funds (SWFs) represent a significant source of investor funds for private equity funds. By some estimates, SWFs have nearly $5 trillion of funds under management.1 An important part of planning for SWF investment in funds is to ensure that U.S. source interest and dividends are exempt from U.S. withholding taxes.
The Internal Revenue Code long has provided such an exemption for interest and dividends received by foreign governments. Temporary regulations were issued in 1988. After 24 years, Treasury has issued proposed regulations that, in some cases, should ease investment by SWFs in private equity funds...............................................Full Article: Source |