blackstone LP (limited partnership)

[joe sod]

I know we are not supposed to discuss specific shares, however this question is about the structure of the investment and not whether or not to invest. Blackstone and other US funds like Oaktree were discussed tonight on RTE in relation to "vulture funds" buying distressed assets in Ireland. You can invest in these on the NY stock exchange however they are not normal shares but limited partnership units. It is advantageous for US investors because their is no dividend witholding taxes , however if you are a foreign investor the US Fed deducts 40% tax (normally it is just 15% for ordinary shares)
Does anyone know much about them, I have a small investment in Blackstone but am probably going to sell it as am unsure how to deal with it in terms of irish taxation. I think I will only get credit for the normal 15% US witholding tax even though 40% was deducted by US tax. But there are alot of asset management companies trading on the NY exchange set up as limited partnerships yet there is little information how to deal with them as a foreign investor

 

[sunnydonkey]

I looked at them previously in the context of the oil industry and shipping, where they are quite common and appear to pay good dividends. They are often used to take assets off a public corporations balance sheet, for better or worse. They are vehicles specifically set up to take advantage of the US tax code so could be a minefield for a foreign tax resident. I never managed to get to the bottom of them as far as concerns a foreign investor. I also believe that the distributions are not pure dividends but a mixture of dividend and return of capital.