Blog | Private Capital Development

Abstract paper-collage diptych of a pendulum first at rest, then released by a small teal pin, representing an action-forcing event.

Action-Forcing Events: Why Some Endowment and OCIO Relationships Move, and Most Don't

PCD: Sep 10, 2026, 5:11:17 PM

Last reviewed: 10 September 2026

A precarious mountain of paper folders and documents with a single blank sheet outlined in teal at the top — paper-collage illustration representing the one PFIC information statement that matters amid a fund's reporting paperwork.

PFIC and the QEF Election: What a Non-U.S. Fund Owes Its Taxable U.S. Investors

PCD: Sep 10, 2026, 5:00:19 PM

A passive foreign investment company (PFIC) is a non-U.S. company that mostly earns or holds passive income and assets. A U.S. taxable investor who...

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

PCD: Sep 10, 2026, 4:58:00 PM

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...

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?

PCD: Sep 10, 2026, 4:55:43 PM

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...

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

PCD: Sep 10, 2026, 4:51:43 PM

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...