Aalok Virmani

Partner
About

Aalok Virmani advises investment fund sponsors on federal income tax matters.  In particular, he focuses on the domestic and international tax aspects of forming, organizing and operating private equity funds, private equity real estate funds, venture capital funds, hedge funds, debt funds and secondary funds. Aalok's practice includes counseling family offices with respect to establishing investment platforms and management incentive arrangements. He also regularly represents clients with respect to GP-led fund restructurings, US and non-US investor representations, secondary transactions and minority investments in fund sponsors.

Aalok spent significant time in-house as a principal at Equity International, a private equity firm that invests in non-US real estate companies. He was responsible for all tax aspects of the firm's portfolio-level transactions, fund formations, sponsor-level tax planning, tax compliance and financial statement reporting. Aalok also held board and audit committee positions at various portfolio companies to help Equity International support and oversee its investments.

Bar admissionsIllinois

EXPERIENCE

Representative fund formations:

  • Food and beverage focused sponsor in the formation of its fifth private equity fund, as well as its second captive subordinated debt fund, raising more than US$1.5 billion.
  • Mid-market industrial focused sponsor in the formation of its initial and second flagship funds, raising more than US$4.25 billion.
  • Non-US biomedical venture capital firm the formation of its fifth and sixth life sciences funds.
  • Energy focused sponsor in the formation of its twelfth natural resources fund, fourth energy transition fund and multiple co-investment vehicles.

Representative fund restructurings and minority investments in fund sponsors:

  • Technology focused venture capital sponsor in a strategic minority investment in the private equity firm.
  • Non-US real estate focused sponsor in a strategic minority investment in the private equity firm.
  • Non-US mid-market sponsor in multiple single-asset continuation funds.
  • Mid-market focused sponsor in a multi-asset continuation fund.

Other representations:

  • Limited partner representations for various types of investors, including sovereign wealth funds, funds of funds and family offices.
  • Leading hedge fund sponsors in the formation of new funds and reorganizations of existing fund structures.
  • Family offices in the design and implementation of long-term capital vehicles, strategic investments, employee compensation arrangements and management companies.
  • While at Equity International, Aalok managed portfolio company acquisitions and dispositions, planned cross-border reorganizations, secured US and local asset step-ups, maximized utilization of foreign tax credits, losses, and other tax attributes, mitigated CFC and PFIC issues, designed and implemented treaty-based holding company structures and operated local country special purpose vehicles. Equity International's portfolio companies were located across Latin America, Asia-Pacific and Europe and operated in a variety of real estate sectors.
Education
  • J.D., University of Illinois College of Law
  • B.S., University of Illinois at Urbana-Champaign

Awards

  • Registered certified public accountant (Illinois)

Bylines

Seminars

  • Speaker, "Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning," Strafford, June 7, 2024
  • Speaker, "GP-led restructurings for SBIC funds," Webinar, April 10, 2024
  • Speaker, "Private Equity Waterfall and Carried Interest Provisions," Stafford, November 2023
  • Co-Presenter, "Advising Family Office Clients on Recurring Legal, Tax, and Business Issues," Strafford Publications Webinar, August 4, 2022
  • Panelist, "Private equity waterfall and carried interest provisions: Economic and tax implications for investors and sponsors," Strafford Publications Webinar, June 2019, September 2020 and October 2021
  • Panelist, "Private equity carried interest clawbacks: Fund agreement mechanisms and tax considerations," Strafford Publications Webinar, March 2019
  • Panelist, "A look at the upcoming new partnership audit rules – What every fund must know," Private Investment Fund Operations and Compliance Forum, July 2016
  • Panelist, "Exploring the potential impact of BEPS on private equity funds – It's not just a corporate issue," The 6th Annual Private Investment Funds Tax Master Class, June 2015
  • Panelist, "Working through common tax implications of foreign investments," The 5th Annual Private Investment Funds Tax Master Class, May 2014

Prior Experience

  • Prior to joining DLA Piper, Aalok was a partner in the tax practice of an international law firm.
  • Equity International, Senior Vice President, Tax
    • Board member, audit committee for SAMHI Hotels
    • Audit committee member, Grupo Acosta Verde
    • Audit committee member, Decameron Hotels & Resorts
  • KPMG LLP, M&A and international Tax practices

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