Teresa Sun Email & Phone Number

Los Angeles, California, US

Los Angeles, California, US

Santa Monica, California, US

Santa Monica, California, US

Santa Monica, California, US

Santa Monica, California, US

• Advise the investment team on ECI, loan origination, FIRPTA, withholding, diligence and structuring related issues.
• Assist the legal team with the review of fund structure and disclosure documents, formation of U.S. and foreign special purpose vehicles, and tax-related investor diligence inquiries and side letter provisions.
• Coordinate with the accounting team and outside service providers to ensure compliance with applicable U.S. and non-U.S. tax and filing obligations.
• Assist the accounting team on the ASC 740 (FIN 48) analysis.
• Assist the operations team on tax-related diligence, KYC, reconciliation and documentation.
• Drafted and update the firm FATCA compliance manual and coordinate with investors relation team, legal team, operations team, fund administrator and U.S. and non-U.S. tax advisers to ensure compliance of FATCA, UK.

Chicago, Illinois, US

• Advised hedge fund and private equity fund clients regarding tax issues relating to fund structure, fund formation and fund investments and drafted tax provisions and disclosures for fund formation and offering.
• Conducted tax research and analysis, drafted memoranda and provided tax advice relating to cross-border restructuring, consolidated return rules, worthless stock deduction, bankruptcy restructuring and debt workout.
• Drafted private letter ruling requests relating to cross-border reorganizations, affiliated group continuation and spin-off.
• Drafted tax opinions and tax disclosures relating cross-border reorganization, recapitalization, reincorporation, tax-free merger and entity classification.
• Drafted and reviewed partnership and limited liability company agreements, merger agreements, stock purchase agreements, asset purchase agreements, membership interest purchase agreements and credit agreements.
• Advised on buy-side and sell-side tax and financing structures in mergers and acquisitions transactions.

London, GB

• Drafted memoranda relating to tax structuring, post-acquisition integration, consolidated return, international tax planning and FIRPTA, PFIC and Subpart F ramifications; drafted private letter ruling requests.
• Conducted tax due diligence on potential targets for private equity and strategic clients to identify potentially material tax issues; drafted tax due diligence reports; provided tax structuring advices relating to.
• Conducted quantitative analyses, including costs and benefits associated with step-up basis transactions, tax attributes, Rev. Proc. 2002-32 deconsolidation/reaffiliation tax impact.
• Conducted research relating to business taxation issues and provided technical assistance to tax consulting and compliance practices.

New York, NY, US

• Performed tax analysis and tax-related diligence capital markets transactions, including REMICs, stock and debt offerings, and debt exchange offers for underwriters and issuers.
• Conducted research and drafted memoranda, private letter ruling requests and other documents relating to taxation of financial products, mergers and acquisition, cross-border tax planning, structured finance and.
• Drafted tax related provisions and tax disclosures in offering documents.
• Assisted in research and the drafting of Brief of Amici Curiae, American Bankers Association et al., Bank One Corporation v. Commissioner.
• Assisted in research and drafting of the article, Beale et. al., An Overview of Federal Income Tax Treatment of Collateral Debt Obligation Transactions, Journal of Taxation of Financial Institutions, July/Aug. 2001.

Ll.M., Taxation

J.D.

Ba/Mba/Macc, Accounting And Finance

Business Administration