Olivier De Moor, Partner, International Tax | Akin

Olivier De Moor

Partner

Areas of Focus

Olivier De Moor, Partner, International Tax | Akin

Olivier De Moor

Partner

odemoor@akingump.com

Areas of Focus

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Biography
  • Represents investment funds and their investors on the U.S. federal tax and tax treaty aspects of cross-border transactions.
  • Advises on international tax aspects of foreign investments by U.S. investors.
  • Extensive experience handling issues under the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS).

Olivier advises hedge and private equity funds on the U.S. federal tax and tax treaty aspects of the structuring and restructuring of their investments in the United States, and cross-border merger and acquisition transactions. His clients also include sovereign wealth funds and high-net-worth individuals.

Olivier regularly provides counsel on the U.S. and international tax aspects of foreign investments by U.S. investors. He advises on a broad range of U.S. withholding issues and has extensive experience handling FATCA and Foreign Bank Account Reporting issues.

Earlier in his career, Olivier practiced as a tax attorney in Belgium before coming to the United States. He is extremely active in the pro bono space, representing refugees and clients under the Violence Against Women Act in immigration law matters. He also advises numerous educational institutions and other tax-exempt organizations in tax matters.

Representative Work
  • Representing fund sponsors on fund formation and separately managed account arrangements, seed investments and fee and carry share structures, and incentive compensation planning.
  • Advising on the U.S. federal tax and tax treaty aspects of loan origination and seasoning, distressed debt strategies, holding structures for debt and warrant instruments, and exit strategies.
  • Providing tax advice on esoteric investment strategies, including credit-linked notes, credit default swaps, tax liens, royalty streams, life settlement assets and cryptocurrency.
  • Counseling U.S. and non-U.S. tax-exempt investors on active business and levered instruments, treaty exemptions and excess business holdings tax issues.
  • Assisting non-U.S. investors in U.S. treaty eligibility, profit repatriation and portfolio interest planning.
  • Advising high-net-worth individuals on U.S. tax issues, including pre-immigration planning.
  • Advising on secondary market and fund restructuring transactions.

Education
  • LL.M., University of Michigan Law School, 2008

  • LL.B., Ghent University, cum laude, 2004

  • P.G.D.L., University of Brussels, magna cum laude, 2005

Bar Admissions
  • New York

Recognitions
  • Chambers USA, Tax, 2024.
  • The Legal 500 US, US Taxes: Non-Contentious, 2022-2024.
  • Akin, New York Pro Bono Counsel of the Year, 2015.
  • The Legal Aid Society, Pro Bono Publico Award for Outstanding Public Service, 2011.
Affiliations and Public Service
  • Member, New York State Bar Association Tax Section Committee on Investment Funds.
  • Member, Akin New York Office Pro Bono Committee
  • Board member, Ghent University Alumni USA.
Speeches and Publications
  • Speaker, “Flex Workers in the US: Pandora’s Box for Canadian Employers?,” Akin Webinar, June 2023.
  • Speaker, “Going International: Tax Issues for Investment Managers expanding into the US or the UK,” Alternative Investment Management Association, March 2023.
  • Moderator, “Expanding the Crypto Investor Universe and Decentralized Finance (DeFi),” Sovereign Wealth Fund Institute Fund Summit, New York, October 2022.
  • Panelist, “Cryptocurrencies: The Developing Regulatory and Tax Landscape for Asset Managers,” Akin NY Private Investment Funds Conference, New York, September 2018.
  • Panelist, “Adapting to Global FATCA: Keeping up the Common Reporting Standard,” HFM Operational Leaders’ Summit, Dallas, May 2016.
  • Panelist, “Common Reporting Standard, Partnership-Level Audit and Other Tax Developments,” Quarterly Roundtable, Akin, Dallas, March 2016.
  • Guest lecturer, International Tax LL.M. Program of the University of Michigan School of Law, Ann Arbor, May 2015.
  • Panelist, “Latest Alphabet Soup of Regulatory and Tax Challenges – AIFMD and FATCA,” Akin NY Private Investment Funds Conference, New York, September 2014.
  • Regular speaker on tax topics, including Series LLCs, partnership audit reform, FATCA and the CRS.

Insights and Achievements

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