Investment Workflow for Korean Investor in US Private Equity Limited Partnership

August 6, 2025

This short memoradum provides a concsie but comprehensive workflow for a South Korean investor seeking to invest in a U.S. Private Equity Limited Partnership (PE LP) through a U.S. C-corporation blocker entity. The primary objective of this structure is to effectively mitigate U.S. tax exposure and compliance burdens for the South Korean investor, while simultaneously optimizing overall returns throughout the investment lifecycle. This analysis addresses key questions regarding the detailed workflow, U.S. tax implications at each stage, management of treaty benefits, impact of diverse investor ownership (including U.S. investors), and essential risk mitigation strategies. 

Disclaimer: The content of the memorandum is provided for general informational purposes only and is not intended to constitute legal, tax, accounting or other professional advice. You should not act or rely on any information herein without seeking the guidance of a qualified professional who is fully aware of your individual circumstances. Neither the author nor the publisher assumes any responsibility for errors or omissions or for outcomes related to the use of this information.