Key Experience

  • Represents investment funds and their investors on the U.S. federal tax and tax treaty aspects of cross-border transactions.
  • Advises on international tax aspects of foreign investments by U.S. investors.
  • Extensive experience handling issues under the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS).

Practice

Olivier De Moor advises hedge and private equity funds on the U.S. federal tax and tax treaty aspects of the structuring and restructuring of their investments in the United States, and cross-border merger and acquisition transactions. His clients also include sovereign wealth funds and high-net-worth individuals.

Representative Work

  • Representing fund sponsors on fund formation and separately managed account arrangements, seed investments and fee and carry share structures, and incentive compensation planning.
  • Advising on the U.S. federal tax and tax treaty aspects of loan origination and seasoning, distressed debt strategies, holding structures for debt and warrant instruments, and exit strategies.
  • Providing tax advice on esoteric investment strategies, including credit-linked notes, credit default swaps, tax liens, royalty streams, life settlement assets and cryptocurrency.
  • Counseling U.S. and non-U.S. tax-exempt investors on active business and levered instruments, treaty exemptions and excess business holdings tax issues.
  • Assisting non-U.S. investors in U.S. treaty eligibility, profit repatriation and portfolio interest planning.

Speeches

Public Service and Affiliations

Recognition