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Covington has many years of experience advising investment funds of various types, including mutual funds, hedge funds, private equity funds and pension funds. Our experience and expertise encompasses structuring issues as well as the selection of appropriate investments in light of the specific tax objectives of the fund.
Covington’s tax practice is nationally recognized for its expertise and experience in the tax treatment of mutual funds and their shareholders and managers. For many years, we have been primary outside tax counsel to the Investment Company Institute, the national trade association for the mutual fund industry. Our clients also include other types of investment funds, including hedge funds, private equity funds and pension funds. We regularly advise these various types of investment funds on sensitive tax issues raised by proposed investments, including qualification issues for regulated investment companies, U.S. trade or business issues for off-shore hedge funds and private equity funds, and unrelated business tax issues for pension trusts and other tax-exempt institutional investors.
Representative Matters
- Advise mutual funds on tax treatment of new financial products.
- Advise pension funds on UBIT issues raised by new forms of credit derivatives.
- Advise off-shore private equity fund with respect to efficacy of FIRPTA “blocker.”
- Representation of the Investment Company Institute on legislative and regulatory matters affecting the mutual fund industry.
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