SPV Tax
The overall investment landscape is rapidly evolving to meet the constantly shifting needs and goals of stakeholders. Most investment structures use Special Purpose Vehicles (SPV) to accomplish their desired outcomes and investment objectives. SPV structures are tax driven, and it is vital to have a knowledgeable tax service provider who understands the tax laws associated with their complex structures (cross-border, multiple investment structure, single/multiple LLC structure, flow-through structure etc.) and their special asset class (real-estate, private investments, alternative investments etc.).
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New Solution Simplifies Tax Calculations, Reporting, and Filings for SPVs
The tax services group at Formidium, a global leader in providing third-party fund administration and back-office technology solutions, announces SPV...
Why SPV Tax ?
SPV Tax is part of Formidium's tax services group. We are a licensed CPA firm in Downers Grove, IL, serving over 350 clients for their tax reporting. 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.
