Collective Investment Vehicles (“CIVs”)

Pooling of assets using CIVs is done to reduce cost, manage risks, and maximize profit for investors while avoiding adverse income tax consequences arising from the joining of investors resident in many different countries.

BSM has represented clients and withholding agents on the US tax consequences arising from pooling billions of dollars of investment assets through a host of different CIVs, including Irish Common Contractual Funds (CCF), Dutch Fonds voor Gemene Rekening (FGR), Luxembourg Fonds Commun de Placement (FCP), and other undertakings for collective investment in transferable securities (UCITS).

BSM works with tax advisors around the world to develop CIVs and harmonize the desired US tax treatment of them with their treatment in the CIV’s country and the countries in which the investors reside.