Represents investment funds and their investors on the U.S. federal tax and tax treaty aspects of cross-border transactions.
Co-leader of the sovereign investment tax practice.
Regularly counsels U.S. clients on U.S. international tax issues, including CFC, foreign tax credit and withholding issues.

Olivier advises private fund sponsors and their investors on the U.S. federal tax and tax treaty aspects of the structuring and restructuring of their investments, specifically focusing on cross-border transactions.

He regularly counsels U.S. clients on U.S. and international tax issues associated with outbound investments, including controlled foreign corporation and foreign tax credit issues, and advises on a broad range of withholding issues.

Olivier is a co-leader of the sovereign investment tax practice, focusing on investments by non-U.S. sovereigns, pension plans and their affiliates, representing these investors across a variety of strategies and asset classes.

Olivier actively engages in pro bono work, representing exempt organizations on tax issues and assisting refugees and other clients on immigration matters. He is fluent in Dutch, French, English and Portuguese, with a good understanding of German and Spanish. Earlier in his career, Olivier practiced as a tax attorney in Belgium before coming to the United States.

Representative Work

Advising Gulf, Canadian and European sovereign and non-sovereign pension plan investors on their U.S. inbound and global investments.
Representing hedge fund and private equity sponsors on fund formation and separately managed account arrangements, seed investments and fee and carry share structures, and incentive compensation planning.
Providing tax advice to hedge funds on esoteric investment strategies, such as cryptocurrency and digital assets, synthetic risk transfers (SRTs), royalty streams, life settlement assets, etc.
Advising on the U.S. and cross-border tax aspects of Brazilian, Mexican and other Latin American M&A transactions.
Assisting non-U.S. investors in U.S. tax treaty eligibility, profit repatriation and portfolio interest planning, including the tax efficiency of U.S. blocker structures.
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 planning.

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.
Vernon E. Jordan Partner Recognition Award, New York Office, 2021.
Akin, Firmwide Transactional Matter of the Year Pro Bono Award, 2020.
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

Board member, Ghent University Alumni USA.
Member, New York State Bar Association Tax Section Committee on Investment Funds.
Member, Akin New York Office Pro Bono Committee.

Speeches and Publications

Speeches

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 timely tax topics.

Publications

“US Presidential Elections 2024—What is at Stake for Swiss Companies and Investors?,” Akin Alert, 2024.
“Update (2): The NY LLC Transparency Act and Corporate Transparency Act’s Impact on Private Fund Managers,” Akin Alert, 2024.
“Hedge Funds Should Take These Steps to Prep for IRS Tax Audits,” Bloomberg Tax, 2023.
“UK Spring Budget 2023: Points for Asset Managers,” Akin Alert, 2023.
“IRS Takes View That FIRPTA Exemption for Publicly Traded Stock Must Be Tested at Partnership Level,” Akin Alert, 2023.
“Full Implementation of Section 871(m) Further Delayed Until 2025: Impacting US Withholding on Swaps over US Stocks and Narrow-Based Indices,” Akin Alert, 2022.
“Structuring Funds for Investment in India: Maximizing Tax Efficiency for U.S. Investors,” EMPEA, 2017.
“Global Information Exchange for Investment Funds: Common Reporting Standard Enters Into Effect,” EMPEA, 2016.