David Richardson

David is a Managing Director in KPMG’s International Tax – Alternative Investments group, specializing in U.S. and non-U.S. tax issues relevant to cross-border funds, investors, asset management companies (including their principals and affiliates), and multinational corporations (i.e., private equity portfolio companies).

David has over 30 years of experience advising clients with respect to international tax issues that arise throughout the life cycle of a cross-border fund.  His clients include private equity funds, credit funds, real estate funds, hedge funds, infrastructure funds, mutual funds, and their U.S. and non-U.S. investors and asset managers. In his U.S. outbound practice, David regularly advises with respect to the U.S. controlled foreign corporation (CFC) and passive foreign investment company (PFIC) rules, with a focus on the interaction of these regimes and potential impacts on investors and fund managers / carried interest recipients. He also advises on the U.S. tax information reporting rules applicable to outbound investments. In his U.S. inbound practice, David frequently advises on withholding on U.S. source passive income, U.S. taxation of effectively connected income (ECI), the use of “blocker” corporations, the portfolio interest exception from U.S. withholding tax, and the Foreign Investment in Real Property Tax Act (FIRPTA) rules. David also advises on the use of tax treaty platforms for structuring U.S. inbound and outbound investments as well as foreign-to-foreign investments.

David is a member of KPMG’s working groups on CFC and PFIC rules (with a focus on post-U.S. tax reform) as well as certain rules arising out of the OECD Base Erosion and Profit Shifting (BEPS) project, particularly as they apply to funds, fund investors, asset management principals, and family offices.

David has spoken at numerous conferences, including those sponsored by the American Bar Association, International Bar Association, Managed Funds Association, Investment Company Institute, Association of the Bar of the City of New York and Harvard Business School.

David’s community service includes longstanding board memberships with Settlement Housing Fund, Inc. and the Center for Talent Innovation, Inc.