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.
Counseling U.S. and non-U.S. tax-exempt investors on active business and levered instruments, tax treaty exemptions and excess business holdings tax issues.
Advising diplomats and other private clients on U.S. tax issues, including pre-immigration, residence and expatriation planning, as well as Foreign Bank Account Reporting (FBAR) and Foreign Account Tax Compliance Act (FATCA) issues.