Having represented various funds, fund managers, trustees and both U.S. and non-U.S. investors, Chapman and Cutler Tax Department attorneys have worked on numerous occasions, with a variety of offshore funding matters and advised clients on how to resolve the legal implications related thereto.

Whether a fund is parallel, stand-alone, in or out-bound, our attorneys are particularly sensitive to the needs of all of our transaction participants.

From an outbound perspective, the Tax Department has repeatedly dealt with tax characterization, foreign tax credit, controlled foreign corporation and passive foreign investment company issues. In-bound funds require insights into doing business, source rules, characterization, withholding, reporting and disclosure issues. We are also comfortable with treaty qualification issues from in-bound or out-bound perspectives.

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