Practical International Tax Implications of Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund for Non-U.S. Private Equity Funds and Their Investors (PDF)
In this Emerging Issues Analysis (EIA), Rufus v. Rhoades and Alexey Manasuev review the recent decision of the Court of Appeals for the First Circuit in Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund, 724 F.3d 129 (1st Cir. 2013) and its implications for non-U.S. private equity funds and their non-U.S. investors with investment portfolios in the United States.
Rufus v. Rhoades is the co-author of Rhoades & Langer, U.S. International Taxation and Tax Treaties, a six-volume treatise published by LexisNexis Matthew Bender. In addition to writing, Mr. Rhoades practices law with a concentration on International Tax matters and in all facets of federal and state income tax matters, including work with the Internal Revenue Service (IRS) and the California Franchise Tax Board on a number of controversial issues. Mr. Rhoades has received the Dana Latham Memorial Award for Lifetime Achievement in Taxation, which was presented by the Los Angeles County Bar Association Section on Taxation, and the Joanne Garvey Award presented by the California State Bar Section on Taxation for substantial lifetime contributions to the field of tax law.
Alexey Manasuev, Partner, U.S. Tax and Cross-Border Tax, TaxChambers LLP, Toronto, Canada. He can be reached at email@example.com. The views and opinions are those of the author and do not necessarily represent the views and opinions of TaxChambers LLP. The information contained herein is general in nature and based on authorities that are subject to change. Applicability to specific situations is to be determined through consultation with your tax adviser.
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