Chen Wei

Chen is a Managing Director in the International Tax Practice in San Francisco, with over 10 years tax consulting and compliance experience. She specializes in cross-border tax planning in multiple jurisdictions, with a focus on alternative investment, credit fund, private equity, and real estate industry.

Professional and Industry Experience

Chen leads consulting and compliance projects for a variety of alternative investment clients, and has experience advising clients on cross-border tax matters, including U.S. outbound investment acquisition structuring, U.S. inbound fund structuring, withholding taxes, cross-border financing, and tax compliance.

Chen has had experience assisting her clients with the following matters:

• Advise on outbound acquisition structuring for alternative investment funds including analyzing U.S. and foreign tax implications, tax reform implications, debt vs. equity considerations, and FIRPTA implications; implementation; funding; legal document review; coordination with foreign offices; and review of transaction decks and research memos.
• Advise on credit and private equity fund structuring, including tax planning for institutional, Section 892, and QFPF investors.
•  Analyze international tax exposure for M&A due diligence projects, including review of GILTI, Subpart F, foreign tax credit, effectively connected income, BEAT, and transfer pricing exposures.
•  Advise on international tax planning for anti-tax avoidance derivative (ATAD), EU mandatory disclosure rules (DAC 6), and Cayman substance requirements.
• Manage large international tax compliance projects for large credit and private equity funds, including advising on tax reform implications including effects of the final GILTI regulations, proposed Subpart F and PFIC regulations, CFC 163(j) netting rules, and BEAT.