Principal, International Tax, Washington National Tax, KPMG U.S. Tax Services (London) LLP
Principal, International Tax, Washington National Tax
Sam is a principal in the International Tax group of the Washington Nationla Tax practice, specializing in tax treaties, fund structuring, international taxation of alternative investments and taxation of financial instruments.
Sam has extensive experience advising U.S. and European asset managers, as well as their investors, with respect to their U.S. fund investment tax matters.
Sam regularly advises asset managers on the U.S. international tax implications of fund formation and fund investment. Sam’s clients include private equity funds, hedge funds, infrastructure funds and credit funds, and often works with funds seeking to expand into different strategies that they may not be as familiar with. He consults on issues throughout the fund lifecycle, including fund formation and specific investor structuring. Sam has experience advising on new fund formations involving LPs, CCFs, ACSs, ICAVs, QIFs, section 110 companies, investment trusts and various Luxembourg and Dutch entities, in both a regulated and non-regulated environment.
Sam often works with funds to accommodate specific international fund investor needs, and in that regard works regularly with non-U.S. pension funds, insurance companies, special treaty investors and foreign sovereign investors seeking to invest in U.S. funds or funds with U.S. exposure. Sam frequently advises on technical issues arising with respect to these clients, including providing written opinions or assisting the client in seeking IRS guidance.
Sam has significant experience advising on loan origination and distressed debt issues for hedge, credit and loan origination funds, particularly with respect to their inbound investment profile. Sam regularly works with some of the largest funds on loan origination issues.