Asset classes within the alternative investment industry What s hot, what s not

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1 Asset classes within the alternative investment industry What s hot, what s not April 2014

2 Contents Introduction... 1 Leading activities... 2 Oil and gas MLPs... 5 Renewable energy investing... 6 Insurance flavored products... 8 Contact information... 9 Asset classes within the alternative investment industry

3 Introduction In response to today s continuing low interest rates, asset managers are exploring new asset classes in search of higher yields. To address this trend within the alternative investments industry, PwC hosted a webcast to provide information on the market activity within specific asset classes, including what is attractive about each class, structuring opportunities and strategies, and the tax implications. The webcast addressed the following four types of asset classes: Lending activities Oil and gas master limited partnerships (MLPs) Renewable energy investing Insurance flavored products As a follow-up to the Nov. 13, 2013 webcast, this document summarizes the issues discussed by a panel of tax and asset management specialists from PwC s Asset Management Tax, Washington National Tax Service, and Cleantech & Sustainable Business Solutions practices. Asset classes within the alternative investment industry 1

4 Leading activities Overview and tax implications In addition to an increase in foreign capital participation, the lending asset class is also seeing an increase in non-traditional lending activities and structures in the market, including: Internet-based lending Distressed mortgage investing Mortgage servicing rights Litigation funding The tax implications of each rely on some of the following basic principles: If a foreign person engages in a US trade or business (USTB) or earns income that is viewed as effectively connected with a USTB (ECI), taxes must be paid on such income. If the fund is viewed as earning ECI, the fund s net income will be subject to US tax at regular corporate rates. An additional branch profits tax can be imposed, which can have the effect of raising the effective US tax rate to approximately 52%. However, if a foreign person does not have a USTB but is a portfolio investor, the income earned may be viewed as fixed or determinable annual or periodical (FDAP) income from US sources, such as US source dividends, subject to a 30% tax on the gross amount of the income. (This income is generally collected via a withholding mechanism.) US tax rules favor foreign persons who invest in US debt securities. The interest on US bonds is generally not subject to the 30% gross basis tax. The portfolio interest exception excludes this interest from tax, subject to some requirements. For example, a foreign bank is not entitled to the benefits of the portfolio interest exception. Additionally, if the investor also holds an equity interest in the issuer, it may not be able to use such exception. A foreign person who frequently or extensively trades in US treasuries or corporate bonds is not deemed to be engaged in a USTB because of safe harbor provisions, which encourage foreign capital investment in the US. Careful consideration should be paid to assure US debt investing meets the requirements of the safe harbor. If a foreign person regularly negotiates the terms of new debt securities with US borrowers and directly purchases those securities from the borrower with cash for its own account, this activity might constitute engaging in a USTB and could fall outside the scope of safe harbor provisions. Consequently, foreign persons typically acquire loans pursuant to operational guidelines designed to ensure their activity constitutes, from a tax perspective, secondary market activity, which is covered by safe harbor provisions. Asset classes within the alternative investment industry 2

5 Internet-based lending An increasing number of hedge funds are showing interest in Web-based platforms that connect borrowers and lenders. These platforms assign a score to a loan/borrower and post it on the Web for a lender to select the web platform enables a process referred to in the market as peer-to-peer lending. These platforms present a number of issues (associated with the existence of a USTB) to foreign lenders who use them to identify borrowers. For example, if the Web-based platform (or a bank) extends the loan, holds it for a few days, and sells it to a hedge fund with no pre-existing commitment to buy the loan, this could be viewed as a secondary market purchase covered by safe harbor provisions. However, if the loan is made to an individual and a foreign fund has committed to its purchase, it might be difficult to conclude that the Web-based platform and bank are not acting as an agent of the foreign fund originating loans with customers on behalf of the foreign fund. Care must be taken to reduce risk when determining whether the loan qualifies for safe harbor. Distressed mortgage investing Distressed mortgages are another popular investment area with potential USTB issues, particularly when the mortgages are purchased with the intention of significant modification, to the point of being deemed a new loan. Institutions that regularly create new loans could be viewed as being in the financing or loan origination business. During the financial crisis, the Managed Funds Association wrote a letter requesting guidance on the USTB question; however, the guidance was never issued. Furthermore, mortgages are not the classic type of security that automatically qualifies for the portfolio interest exception. If held directly by a foreign person, the interest may be subject to 30% withholding tax. Broadly, three approaches are typically considered by foreign market participants seeking to invest in distressed mortgages. They are: 1. Domestic blocker: Put in a US corporation, leverage it as much as possible, and pay full tax. 2. Foreign corporate holder: This may require putting mortgages in a trust to assure the portfolio interest exception can be claimed. 3. REMIC structure: There are limits to this type of structure. Mortgage servicing rights When the originator of a mortgage sells the loan to an entity such as Fannie Mae, it can retain the mortgage servicing rights (MSRs) and can receive compensation for those services. When the original bank/originator sells the loan (retaining the MSR), it must distinguish the normal fees from the excess amounts; for tax purposes, the excess amounts are treated as an interest only bond (IO) that is retained by the bank and the normal fees are treated as fees for services. So if the bank originates a mortgage and retains excess MSRs, it must allocate some of its tax basis in the mortgage to the IO bond strip that it retains. Asset classes within the alternative investment industry 3

6 Many banks and servicing companies have started selling some or all of these MSRs to third parties including hedge funds. When a foreign hedge fund buys a number of basis points (bps) of an MSR, it must be determined whether it is also purchased some portion of the service fee. If it is decided that it is splitting services income with the servicer, this could create a USTB and be subject to US tax. In this case, hedge funds that purchase MSRs must be careful that they are buying debt and not service fees. However, even if the fund becomes comfortable at the time of purchasing the MSRs, things can change to create new issues. If the mortgage is renegotiated, the servicer often retains the right to service the new loan. Frequently, the hedge fund will negotiate that it also owns a portion of this new MSR. This creates the loan origination issues discussed earlier, and the hedge fund may own a new IO strip/loan with new loan origination issues. Litigation funding As background, when plaintiffs pursuing lawsuits in the United States need funding, they are often prepared to give up a portion of the future recovery in return for financing. There are certain ECI risks that should be considered. The questions/issues include: Is the arrangement between the fund and a plaintiff properly characterized as a partnership for US tax purposes? If so, is the partnership s activity properly viewed as: (i) the mere prosecution of the claim (which may, or may not, be a USTB), or (ii) the plaintiff s larger commercial activity that gave rise to the claim (which would likely be a USTB)? Is the fund properly viewed as a co-owner (with the plaintiff) of intangible property (the legal claim)? If so, is the other co-owner s activity in prosecuting the claim (i.e., the activity of the plaintiff and its lawyers) properly viewed as activity of the fund (i.e., as agent for the fund)? If so, is this activity sufficient to qualify as a USTB? Regardless of how the prior issues are resolved, how does the origin of the claim doctrine apply? Broadly speaking, this doctrine characterizes taxable income earned in a lawsuit by reference to the activity that gave rise to the claim. It is generally applied to make capital versus ordinary distinctions but can it be extended in the international context so that income that is characterized as ordinary business income in the hands of the plaintiff is so characterized in the hands of the fund (as co-owner)? Is the fund s activity in the US properly viewed as investment activity, or is the fund in a financing business? Are the plaintiffs and their lawyers properly viewed as customers of the fund? Does the fund hold itself out to the US public as a source of financing? Asset classes within the alternative investment industry 4

7 Oil and gas MLPs Overview and history Publicly traded partnership (PTP) rules drafted years ago to spur private investment in natural resources and domestic energy have fostered growth seen in the MLP industry today. The stable yields and tax-efficient structures continue to attract fund investors, which have traditionally been largely US domestic investors. However, foreign investment is increasing, with overseas-based funds forming to invest within the MLP market. MLP products span most of the energy industry s value chain and take various forms. While MLPs can take various forms, most of them are PTPs for tax purposes, which can flow through ECI, unrelated business taxable income (UBTI), and state sourced income to investors. Blocker corporations may be used to hold MLPs, but they are usually subject to full corporate tax rates. Foreign funds often use derivatives to gain exposure to MLPs. When properly structured, derivatives provide leverage, minimize economic exposure, and provide counterparty exposure, among other things. Please read Taxation of MLPs: The Long and Short of It for a more detailed discussion on the taxation of MLPs through. Additional approaches to investing There are alternatives to investing in MLPs besides directly or through derivatives. Some of these are as follows: Variable annuities are another way to gain introduction to MLPs without ECI/UBTI exposure. The economics are similar to a total return swap, but in this case, a security (the annuity) is issued by an insurance company that tracks the performance of a separately held portfolio of MLP securities. The benefit of this investment over a total return swap is lower structuring costs. However, using properly structured derivatives or annuities does not alleviate Foreign Investment in Property Tax Act (FIRPTA) concern, which can exist if ownership is greater than 5% and should be closely managed. Widely held fixed investment trusts (WHFITS) are being used by managers as an alternative to a partnership vehicle and offer investors access to MLP investments without the higher cost and the reporting requirements of partnerships, or the registration requirements of a unit investment trust. Collective investment trusts (CITs) provide an attractive investment option for UBTI-sensitive corporate pension funds. In this structure, a partnership invests in MLPs and takes on investors. Investment managers view the CIT as a more taxefficient vehicle through which these plans can invest. A ruling from the IRS approving the CIT is required before the CIT can go live, so it is important to work with advisors that have experience in these entities. The power of the CIT is that the only tax leakage occurs on UBTI income. Pension plans can think of this as a washer UBTI tainted income comes into the CIT, the UBTI is taxed and withheld at that level, and the rest of the income is passed through, at pre-tax levels. This eliminates the full tax hit with a corporate blocker and provides for attractive pass-through treatment of all good income to the pension plan. Currently, this applies only to corporate pension plans, but work is taking place on CIT applicability to other entities, such as charitable endowments. Stay tuned. Asset classes within the alternative investment industry 5

8 Renewable energy investing Overview There is growing interest in renewables as an asset class, not only among the traditional bank investors who finance these projects but also among other investors as well. The industry has matured over the past five years, and the US Energy Information Agency estimates renewables will account for about a third of all new electric generating capacity built between now and There are opportunities for both traditional and non-traditional investors to provide construction period project finance and longer-term tax equity finance. Because state and federal incentives are still an important part of the capital for these projects, it s important to stay abreast of developments in this area. Also, these incentives create some interesting issues for alternatives investors so they can obtain credits and use them in a way that makes them attractive for tax-exempt investors as well. Key drivers Historically, the industry has been driven by incentives, such as the 30% investment tax credit or the production tax credit. In recent years, solar and wind power have achieved grid parity in a number of state-specific markets, i.e., generating electricity at a cost that is less than or equal to purchasing power from the electrical grid. As the price of solar panels continues to drop, grid parity will likely expand to more and more jurisdictions, even as tax credit support declines. Many in the industry feel confident they ll be able to achieve grid parity by 2016, which is when many solar investment tax credits will expire. Investment benefits Funds that focus primarily on individuals and tax-exempt investors could still find investment opportunities in niche areas such as construction period financing (debt financing, mezzanine type lending) where there is little concern about monetizing tax credits. In these cases, the tax equity is provided by someone else. Tax equity is a form of financing that relies on bringing in an outside party with taxable income to monetize the tax credits generated by a renewable energy project. Because many renewable energy project developers are start-up entities without enough tax liability to use the tax credits, they bring in a financing party to take the tax credits in return for providing financing for the project. There are three basic structures for accomplishing tax equity financing: partnership flips, sale-leaseback, and inverted lease structures. Partnership flips The term flip refers to a change in the allocation percentages of taxable income, and losses and credits between the two parties to the transaction over the life of the partnership. For example, 99% of the initial allocation of income, losses, deductions, and credits goes to the tax equity investor, the party providing the financing, and 1% goes to the developer, the party that knows how to build and run the facility. Although the tax allocations are 99/1 in this early period, cash distributions typically are more generous to the developer, which needs cash distributions to finance its Asset classes within the alternative investment industry 6

9 operations. After a predetermined amount of time at least five years to avoid recapture of the investment tax credits, or the achievement of a targeted internal rate of return the initial 99/1 allocations flip so that the financing party gets only 5% of all of the tax economics of the transaction and the developer takes 95% of the taxable income and associated deductions. The flip mechanism allocates nearly all of the investment tax credits and accelerated depreciation in the first five years of a project and allows them to be used by a party that has tax liability. Sale-leaseback and inverted lease structures There are two other related structures to ensure the ownership of the property for federal income tax purposes is in the hands of someone with tax capacity when the tax benefits accrue. One is the sale-leaseback and the second is the inverted lease structure. With the sale-leaseback, care must be taken to structure them so they are treated as true sale and leaseback transactions rather than as financing leases. In the typical pattern, the investor purchases the power-producing equipment from the developer, claiming the credits and associated depreciation. The developer leases the equipment and enters into a power purchase agreement. Sale-leaseback, like partnership flips, usually have an exit option that is 5 1/2 to 6 years and after the tax credit recapture period. The inverted lease is similar to a sale-leaseback, but it relies on a provision in the tax code that allows investment tax credits to be assigned to a lessee of investment tax credit property. These structures are sometimes used when the parties need to get the federal tax benefits and the state tax benefits into the hands of different investors. MLP parity Under current law, MLP treatment is not available for renewables, but there is a Senate proposal (the MLP Parity Act ) to allow such treatment. While many in Congress generally agree with the goals of the MLP Parity Act, it does not appear that this is a near-term priority. However, it is important to note that MLP parity could be enacted as part of a broader tax reform package that could include cuts to or even elimination of various tax incentives and governmental subsidies for renewable energy. In that sort of legislative tradeoff, we would expect to see wind power as a likely early winner because that wind is the most mature renewable technology, with established infrastructure and costs nearing grid parity with conventional utilities. Asset classes within the alternative investment industry 7

10 Insurance flavored products Overview There are two insurance flavored products that have gained traction over the past few years: Insurance Dedicated Funds (IDFs) and the Reinsurance Model. Insurance Dedicated Funds There has been a push by high net worth taxable investors in the United States to invest through insurance policies/annuities. This emerging trend is prompting many fund managers to set up insurance dedicated funds to accommodate rising investor interest. IDFs are hedge funds that are wrapped with a variable annuity or life insurance policy. In other words, the domestic taxable investor invests in an insurance product such as a variable annuity whose performance is tied to the specific IDF. This is really no different from an insurance product such as a variable annuity wrapped over an investment in a mutual fund. The primary tax effect is that the investor is taxed under insurance company rules. Specifically, there are no taxes until fund realizes gain (that is, the investor is allowed tax-deferred inside build-up ); and is only taxed when cash is distributed. Further, death benefits can be excluded from taxable income. This can be quite attractive for hedge fund strategies that are not tax-efficient, such as 475(f) funds, for example. It s also possible to have insurance products wrapped over managed accounts instead of insurance deducted funds. In this case, consideration must be given to the investor control rules that apply to insurance products. Reinsurance Model It is possible for the master fund to be organized as a foreign corporation engaged in a reinsurance business. Done properly, the reinsurance business can qualify the fund to be an insurance company for US tax purposes. Under special subpart F and PFIC rules, US investors in offshore insurance companies can enjoy deferral on the investment returns from investments assets associated with the insurance business. There are a number of tax issues to consider with the reinsurance model including: (i) its qualification as an insurance company for tax purposes, and (ii) making sure that the investment capital is appropriate for the insurance business being carried on. Asset classes within the alternative investment industry 8

11 Contact information For more information please contact: Kara Friedenberg Partner, Asset Management Tax Alan Biegeleisen Managing Director, Asset Management Tax David Shapiro Principal, Washington National Tax Service Jeffrey Maddrey Principal, Washington National Tax Service Matthew Haskins Principal, Cleantech Asset classes within the alternative investment industry 9

12 PricewaterhouseCoopers LLP, a Delaware limited liability partnership. All rights reserved. Solicitation PwC refers to the US member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see for further details. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisers.

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