Investor Representation

• Represented institutional investors—including endowments, foundations, pension plans, family offices, sovereign wealth funds, and funds of funds—in private equity, venture capital, and alternative investment activities. Transactions include co-investments, funds of one, GP-led restructurings, and secondary transactions, with deal sizes generally ranging from $15 million to $300 million per investment.

• Negotiated tax-efficient partnership agreements, side letters, and subscription documents for institutional investors across private equity and venture capital funds.

• Represented a Southeast Asian sovereign investor in two secondary sales of large fund portfolios valued at approximately $1.7 billion and $2.1 billion, respectively, addressing tax structuring for efficient exits.

Tax Transactions and Planning

• Designed bespoke tax strategies for private equity funds managing over $2 billion in assets, optimizing fund structures to minimize withholding taxes and maximize investor returns.

• Structured hybrid investment instruments to achieve favorable tax treatment for institutional investors with cross-border exposure in North America, Europe, and Asia.

• Developed tax-efficient cross-border structures for corporations and fund managers to minimize exposure and ensure compliance.

• Advised fund sponsors on tax implications of GP-led restructurings and recapitalizations, ensuring compliance with U.S. and international tax regulations.

• Provided strategic guidance on transfer pricing arrangements and intellectual property migrations, resulting in measurable tax savings.

Fund Formation and Structuring

• Advised fund sponsors on the formation and structuring of private equity and venture capital funds, including parallel and feeder fund arrangements, raising over $500 million in aggregate commitments.

• Designed tax-efficient fund structures for emerging managers in high-growth sectors such as biotechnology and agritech.

• Counseled a global private equity sponsor on a $1 billion fund-of-one arrangement with a sovereign wealth fund, negotiating bespoke terms and ensuring compliance with tax regulations.

Emerging Businesses and Venture Financing

• Tax-Efficient Structuring: Designed entity structures to facilitate funding rounds and optimize tax outcomes for startups and scaling companies.

• Venture Financing: Negotiated venture capital financing agreements to ensure favorable terms for both founders and investors.

• Cross-Border Growth: Supported emerging businesses in expanding their global footprint, addressing regulatory compliance, and structuring operations for efficiency.

Secondary Transactions

• Represented an institutional investor consortium in a $1.4 billion recapitalization of a legacy private equity fund sponsored by a North American alternative asset manager.

• Structured a $500 million secondary sale and portfolio restructuring for a pension fund, addressing complex fund valuation and tax optimization strategies.

• Advised a U.S. asset manager in the sale of over 50 fund interests during the liquidation of a multi-billion-dollar fund-of-fund vehicle.

Cross-Border Transactions

• Advised fund managers and institutional investors on cross-border investments in EMEA, Asia, and Africa, structuring deals exceeding $1 billion to minimize tax exposure and navigate regulatory frameworks.

• Provided strategic guidance on transfer pricing arrangements and intellectual property migrations, resulting in measurable tax savings.

• Represented an Asian investment manager in acquiring a controlling stake in a fintech portfolio company, addressing multi-jurisdictional tax structuring and regulatory compliance.

Impact Investing and Agritech

• Structured $250 million in ESG-aligned agritech investments, targeting renewable energy projects and sustainable agriculture initiatives.

• Advised an impact fund sponsor on governance and compliance frameworks for a $150 million fund investing in high-growth markets in sub-Saharan Africa and Southeast Asia.

• Represented institutional investors in structuring co-investments into agritech startups focused on sustainable food production and climate adaptation technologies.

Capital Markets and SPACs

• Represented SPAC sponsors in forming and launching IPOs with aggregate proceeds exceeding $1 billion, ensuring compliance with U.S. securities laws.

• Structured and advised on private placements and Regulation S offerings for investment funds, raising over $500 million in growth capital.

• Drafted SEC disclosures and tax provisions for the issuance of debt and equity securities by U.S. and international issuers.

The above transactions are representative of Daphny’s matters prior to her founding Lazarus.