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Investor Presentaiton

Additional Considerations Attention should be paid to the local adviser regulation and local tax implications of Dual-Hatting personnel in a given country The presence of Dual-Hatting personnel in a country may raise (i) permanent establishment tax issues for the US-Registered Investment Adviser (RIA) and (ii) questions about whether the US RIA has to be authorized in the foreign jurisdiction ✰ There may be alternatives to relying on Participating Affiliate arrangements that present less risk 。 Foreign advisers may register under the Advisers Act and serve in subadviser or co-adviser arrangements with US affiliates О Consideration may be given to registering as a "relying adviser" attached to the registration of the US affiliate, although proposed regulations would then require Advisers Act compliance with respect to both US and foreign clients 。 Foreign advisers may substantively comply with Advisers Act requirements with respect to foreign clients Morgan Lewis 50
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