Key Experience

  • Represents investment funds and their managers.
  • Poised to assist clients with new partnership-level income audit rules and other tax changes resulting from the Tax Cuts and Jobs Act.

Practice

Christopher Harvey advises clients as to tax issues relating to the formation, operation and restructuring of domestic and offshore private investment funds, including hedge funds and private equity funds. He also advises fund portfolio companies as to various tax issues, including in relation to their debt workouts and recapitalizations.

Representative Work

  • Helped a client structure its debt retirement to avoid incurring “phantom” taxable income.
  • Advised a client as to the tax aspects of a debt-for-equity exchange and the impact on the client’s post-exchange taxable income and tax attributes.
  • Assisted a client in structuring its add-on debt offerings so that the add-on debt was fungible for tax purposes with its existing debt.

Guided a NASDAQ-listed company as it raised funds for its flagship private equity fund, negotiating investor-side letters with tax provisions and resolving tax issues for the fund to meet its fundraising targets.