Taxation
A. Tax structure (illustrative – consult your tax advisor)
For US Investors:
- Funds structured to avoid UBTI (unrelated business taxable income)
- K-1 reporting for partnership pass-through taxation
- Carried interest potentially subject to partnership taxation rules
- Recommend consultation with tax counsel regarding Section 871(m) implications
For EU Investors:
- Luxembourg RAIF / German GmbH & Co. KG structures for tax efficiency
- VAT exemption for fund activities
- Dividend withholding varies by investor jurisdiction
- Recommend consultation with local tax authority
For Asian Investors:
- Singapore-based structures available (Allocator One expansion plan)
- Alternative fund vehicles may be available
- Treaty benefits apply based on domicile
B. Tax documents & reporting
Provided by Allocator One:
- Annual K-1 (US) or equivalent schedule (EU/Asia)
- Tax basis reporting and cost allocation
- Distributed earnings statement
- Form W-9 / withholding certificate (if applicable)
Investor Responsibility:
- Consult tax counsel regarding jurisdiction-specific treatment
- File annual tax returns reflecting Fund income/losses
- Maintain records for audit purposes