SPV Tax
The investment landscape is swiftly changing to match stakeholders' dynamic needs. Special Purpose Vehicles (SPVs) are common in investment structures, serving specific goals. Given their tax-driven nature, a proficient tax provider is essential. This expert should grasp intricate tax laws related to diverse structures (cross-border, multiple LLCs, flow-through, etc.) and special asset classes (real estate, private investments, alternatives).
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Workflow for Investment Fund
Year-End Tax Returns
This video illustrates the workflow for Investment Fund Year-End Tax Returns, the process follows the execution of a service engagement between our clients and us, and concludes upon the submission of tax returns to the relevant tax authorities, including forms like 1065, 1040, 1120, and 1120-S. Additionally, we ensure the distribution of tax statements to Investors and vendors, such as Schedule K-1, Form 1099, and 1042-S.
Why SPV Tax ?
SPV Tax is part of Formidium's tax services group. We are located in Downers Grove, IL serving the tax reporting needs of over 600 clients and have licensed CPAs leading our tax practice. We offer our all-inclusive tax services to a vast network of managers and SPVs globally, covering asset classes like real estate, private equity, and other alternative investments. Our experienced and qualified service team of 50+ individuals take good care of your SPV tax filings and reporting of scheduled K-1s for your investors.
Using our proprietary technology and extensive research, our tax specialists provide you with industry-leading tax support coupled with the highest level of client service because cutting-edge technology and high-touch client service is at the core of everything we do.
Services we offer
We provide comprehensive tax services across SPV's entire lifecycle, as described below:
- Review of private placement memorandum tax section.
- Preparation of U.S. federal returns (1065, 1120, 1120-S) and state tax returns for all U.S. states, including composite tax returns, handling state filing fees, etc.
- Preparation of all supporting and additional tax forms that are filed along with federal and state tax returns. (Form 8949, 4797, 8825, 8990, 8082, 8832-B, etc.)
- Preparation of federal and state schedule K-1 reporting for investor.
- Partner tax allocations using appropriate allocation methods.
- Preparation and compliance with foreign investments. (Form 5471, 8865)
- U.S. tax reporting and compliance for Non-U.S. investors. (Form 1042, 8804, 8805)
- Preparation of international reporting tax forms K-2 and K-3.
- Preparation of other miscellaneous forms like Form 1099s, name change, address change forms, and many more.
- Preparation of responses to IRS and state revenue notices.
- Offering and organizing cost amortization, book-to-tax reconciliations, maintaining tax basis for investors' capital and SPV’s investment, and handling the assignment of interest from one investor to another.
- Tax lot level capital gain/loss calculations, wash sales calculation.
- Unrelated business taxable income (UBTI).
We provide comprehensive tax services across SPV's entire lifecycle, as described below:
- All the items covered for U.S. SPVs.
- Preparation of foreign partnerships and blocker corporations' tax returns, including foreign master-feeder structures.
- Analysis of SPV’s structure to determine its applicable U.S. tax filings. (Passive foreign investment company vs. controlled foreign corporation determination)
- Filing applicable tax forms for non-U.S. SPV, including Form 8621, 5472 reporting.
- Preparation of K-1 equivalent forms for Non-U.S. SPV’s investors, including PFIC/CFC reporting.
We provide specialized tax services tailored to the requirements of SPVs including analysis and tax adjustments for:
- Schedule K-1 received from upper-tier SPV (including multiple upper-tier investments)
- Waterfall distributions for tax allocation.
- Committed capital structures.
- Business interest expense limitations.
- Qualified business income deduction.
- Global intangible low-taxed income. (GILTI)
- Foreign-derived intangible income. (FDII)
- Carry rules under section 1061.
- Qualified small business stock analysis under section 1202.
- Itemized deductions and net operating losses.
- Expensing/depreciation.
- Effectively connected income and withholdings.
- State source income apportionment factor calculation, state tax withholdings, etc.
