https://www.oaklandinstitute.org/war-th ... tural-land
The report identifies many prominent investors, including Vanguard Group, Kopernik Global
Investors, BNP Asset Management Holding, Goldman Sachs-owned NN Investment Partners Holdings,
and Norges Bank Investment Management, which manages Norway’s sovereign wealth fund. A
number of large US pension funds, foundations, and university endowments are also invested in
Ukrainian land through NCH Capital – a US-based private equity fund, which is the fifth largest
landholder in the country.
Most of these firms are substantially indebted to Western financial institutions, in particular the
European Bank for Reconstruction and Development (EBRD), the European Investment Bank (EIB),
and the International Finance Corporation (IFC) – the private sector arm of the World Bank.
Together, these institutions have been major lenders to Ukrainian agribusinesses, with close to US$1.7
billion lent to just six of Ukraine’s largest landholding firms in recent years. Other key lenders are
a mix of mainly European and North American financial institutions, both public and private. Not
only does this debt gives creditors financial stakes in the operation of the agribusinesses, but also
confers a significant level of leverage over them. This was evidenced by the debt restructuring of
UkrLandFarming, one of Ukraine’s largest landholders, which involved creditors including the
Export-Import agencies of the US, Canada, and Denmark, among others,
and led to important organizational changes including layoffs of thousands of workers.
https://www.oaklandinstitute.org/sites/ ... l-land.pdf
"The endowments at Penn, Harvard & MIT have a combined $95B+ in assets - yet only pay a 1.4% tax rate on net investment income,
" Vance posted on X. "Then they use these funds to push DEI and woke insanity."
Blocker corporations to convert taxable gains into exempt income streams like interest rent and dividends.
The grift will continue untaxed for the uniparty drones.
“Rollover Equity Transactions 2019,” we discussed the various business and tax issues associated with transactions involving private equity (PE) buyers who include rollovers of target owner equity in their leveraged buyout (LBO) transactions. Here, we take a deeper dive into the ramifications of having some PE investors invest in target companies through blocker corporations.
What are “blocker corporations?”
Blocker corporations are corporations that effectively “block” taxable income at the corporate level for U.S. federal, state and local income tax purposes. When a PE firm structures an LBO transaction, some PE investors, generally tax-exempt and foreign investors, will invest directly or indirectly in portfolio company equity through one or more newly-formed Delaware C corporations (the blocker corporation). The right of tax-exempt and foreign investors to use blocker corporations and provisions protecting the economic rights of tax-exempt and foreign investors are often spelled out in PE firm’s fund documents and limited partnership agreement.
Why are “blocker corporations” used when a PE fund invests in a U.S. based business taxed as a partnership for federal income tax purposes?
Taxable income passed through on a Schedule K-1 by a portfolio company generally falls into the category of income “effectively connected with a U.S. trade or business” for foreign investors and unrelated business taxable income (UBTI) for U.S. tax-exempt investors. Foreign investors want to avoid being allocated effectively connected income because exposure to an allocation of that income subjects them to a U.S. income tax filing requirement and potentially to U.S. federal income and withholding taxes. Tax-exempt investors want to avoid being allocated income that is UBTI because that income will subject the otherwise tax-exempt investor to U.S. excise taxes. So, neither foreign or tax-exempt investors want to hold directly an equity interest in a U.S. business taxed as a partnership. Hence, the use of a U.S C corporation as a “blocker corporation” to block the flow-through of income on a Schedule K-1 at the corporate level.
If all of the requirements of Section 1202 are met, each individual taxpayer might qualify for at least a $10 million gain exclusion with respect to the sale of an issuing corporation’s stock. The application of Section 1202 to portfolio company investments and equity rollover arrangements has not been fully explored and certainly represents an interesting opportunity for tax savvy PE firms and venture capitalists.
Juice boxes grift to uniparty and yes do ignore the spending issues as you screw the taxpayer's sideways up down left right with the body farm adrenochromed failed zombies.
We are not buying your esg cra garbage from your greenwash and greenmask marxist failed in life try hell reprobates.
As the marco polo reports indicate the rot has blew past corrupt. Worships evil to distract the crayon chewers.
