In this article we examine the increasing use of side fund letters in a private investment funds context and the associated most favoured nations (MFN) process. We consider the tax provisions being used in side letters and suggest two developments (one tax-specific and one more general) which we consider will make the side letter negotiation and MFN process more manageable and ultimately less costly.
Side letters are a contractual means by which fund managers can grant rights to investors which...
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In this article we examine the increasing use of side fund letters in a private investment funds context and the associated most favoured nations (MFN) process. We consider the tax provisions being used in side letters and suggest two developments (one tax-specific and one more general) which we consider will make the side letter negotiation and MFN process more manageable and ultimately less costly.
Side letters are a contractual means by which fund managers can grant rights to investors which...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: