Practice focuses on the tax aspects of investment management across the spectrum of alternative investment funds, including private equity funds, private credit funds, hedge funds, secondary funds, hybrid funds, evergreen funds, family offices, royalty funds, fund of funds and real estate funds.
Advises clients on a broad range of U.S. and international tax matters, including tax considerations in fund formations and corporate transactions, with an emphasis on transactions involving investment funds across asset classes, including private equity, credit, real estate and royalties.
Provides counsel through all phases of the fund life cycle, from fund formation to investment and transaction activity to operational and succession planning.
Counsels alternative investment fund managers on the tax aspects of “upper tier” arrangements and transactions.

David advises clients on the tax aspects of investment structures and business transactions with an emphasis on cross-border planning, domestic and international mergers & acquisitions (M&A), joint ventures and partnerships.

Serving as lead tax counsel, David routinely represents large, multinational, multi-strategy alternative investment fund managers on the U.S. and international tax aspects of their investments and transactions. David represents global asset managers spanning the spectrum of funds, including private equity funds, private credit funds, hedge funds, secondary funds, hybrid funds, evergreen funds, family offices, royalty funds, fund of funds and real estate funds.

David regularly assists clients in the structuring and restructuring of domestic and international investments and negotiating corporate acquisitions in both the domestic and cross-border contexts.

Clients rely on David for bespoke tax structures tailored to his clients’ investment strategies and business objectives. In addition, David represents fund managers on upper-tier structuring and transactions. David also represents clients, including funds and fund managers, in connection with complex tax controversies and other contentious tax matters.

Representative Work

Representing numerous global asset managers in serving as lead tax counsel on fund formations, investments, transactions and operations worldwide.
Representing leading alternative investment managers in advising on planning and negotiating domestic and international business transactions, corporate and financial tax counseling.
Represented ProKidney, a leading clinical-stage cellular therapeutics company focused on chronic kidney disease, in its $2.64 billion business combination with Social Capital Suvretta Holdings Corp. III.
Represented Royalty Pharma plc on its $2.5 billion IPO and listing on the Nasdaq Global Select Market.
Represented TPG Angelo Gordon in the fundraising of AG Asset Based Credit Fund LP with more than $1 billion of equity commitments. The fund received significant support from existing Angelo Gordon clients, as well as new institutional investors attracted to the firm’s demonstrated ability to generate value through private credit strategies globally.

Represented Crayhill Capital Management, a New York-based, minority-owned private credit manager focused on asset-based investments, in the closing of $820 million of capital commitments.
Represented Pharmakon Advisors LP in its $450 million financing commitment to BioCryst Pharmaceuticals, Inc. BioCryst Pharmaceuticals discovers novel, oral, small-molecule medicines that treat rare diseases in which significant unmet medical needs exist and an enzyme plays a key role in the biological pathway of the disease.
Represented Pharmakon Advisors LP in its new five-year up to $400 million committed senior secured credit facility for Novocure.
Represented Pharmakon Advisors LP and its affiliated funds in a $200 million senior secured credit facility to Tarsus Pharmaceuticals Inc., whose mission is to focus on unmet needs and apply proven science and new technology to revolutionize treatment for patients, starting with eye care.
Represented Paine Schwartz Partners, a private equity fund specialized in sustainable food chain investing, in its strategic growth investment in Elemental Enzymes, a leading developer of naturally occurring enzymes and biochemicals contributing to improved plant health, yield and profitability.