PCD

The same armchair with a teal cushion repeated across four different paper-collage backdrops — illustration representing a constant baseline tax reporting obligation carried across changing layers of added requirements.

Schedule K-1, K-2, K-3, and Form 8865: The U.S. Tax Reporting a Non-U.S. Fund Must Deliver

A non-U.S. fund treated as a partnership for U.S. tax purposes owes each U.S. investor a Schedule K-1 annually. Since 2021, most funds with international items also deliver Schedules K-2 and K-3, which break out foreign-source income and foreign...

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A figure stands before a series of successively narrower stone doorframes leading to one small glowing teal doorway in the distance — paper-collage illustration representing how specific fund activities narrow the path toward effectively connected income exposure, while most funds pass through freely.

What Is Effectively Connected Income, and Does It Apply to a Non-U.S. Fund Manager?

Effectively connected income (ECI) is income a non-U.S. person earns from a U.S. trade or business, taxed the same way a U.S. person's business...

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A locked trunk with multiple padlocks and one small glowing side hatch open, releasing a folded document — paper-collage illustration representing a blocker structure that seals off business income while letting a clean dividend through.

UBTI and the Blocker Structure: What a Non-U.S. Fund Owes Its Tax-Exempt U.S. Investors

UBTI is the slice of a U.S. tax-exempt investor's income — endowments, foundations, most pension plans — that the tax code treats as if it came from...

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Abstract paper-collage illustration of a blizzard of envelopes converging on one narrow mail slot, representing attention rather than mail volume.

Cold Outreach to an Endowment CIO: What Actually Happens to the Email

Last reviewed: 10 September 2026

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Abstract paper-collage illustration of a stone column beneath a long horizontal beam, with a small seedling growing at its base, representing permanence and patient long-term growth.

How a Fund Manager Actually Gets in Front of an Endowment or Foundation

Last reviewed: 10 September 2026

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Abstract paper-collage illustration of a sealed vault door beside a small open side hatch, representing a liquidity side door.

What Endowment Spending-Policy and Liquidity Constraints Mean for How You Pitch

Last reviewed: 10 September 2026

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Abstract paper-collage illustration contrasting a complete chart on one side with only a torn corner on the other, representing information asymmetry.

The 2026 Endowment Allocation and OCIO Numbers, Reconciled

Last reviewed: 10 September 2026 — figures included as of 12 February 2026 (2025 NACUBO-Commonfund Study of Endowments)

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Paper-collage illustration: one figure holds a complete map, the other only a torn corner — the information asymmetry between an introducer and the investor receiving an introduction.

Who Pays for GP Intro? Is It Free to You the Investor?

Last reviewed: 4 September 2026

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