Carry is the whole point of the fund for a GP. And its economics are decided the day you create it.

• You are launching a fund or becoming a GP and receiving carried interest for the first time.
• The GP team sits across several countries, and each manager has their own residence.
• The fund structure must be set so that it holds both at the first distribution and years later.

What the House does

The House builds the GP structure and the carry vehicle around your team and the fund’s strategy — so that distributions reach the managers without destructive tax and without surprises at the first successful exit.

• The architecture of the GP and the carry vehicle around your team and the fund’s strategy.
• Carry tied to each manager’s residence, so the income is not taxed twice.
• The choice of fund and GP jurisdiction with the investors and future distributions in mind.
• The contractual and tax logic of the waterfall before launch, not after the first exit.
• The managers’ personal reporting in their respective jurisdictions, brought together as one.

What you get: the architecture of the GP and the carried-interest vehicle for the fund team · carry tied to each manager’s residence · a waterfall memo with the contractual and tax logic of distribution · the managers’ personal reporting in their respective jurisdictions, brought together

Why this way and not another

• The fund lawyer assembles the fund documents but does not build the GP’s personal tax position.
• Carry set up “like everyone else’s” ignores the residence of the specific managers.
• To untangle the structure at the first distribution is to be years too late.

What worries you — and the House’s answer

• “Tax will devour the carry at the very first exit.” — The carry vehicle and its link to residence are built before launch, around the distribution.
• “Our GP sits in different countries — it will never reconcile.” — Each manager is tied to their own position, and the structure brings them together as one whole.
• “The investors won’t accept our fund structure.” — The GP and fund jurisdiction is chosen with the investors in mind, not against them.

Where this leads

The GP structure stands; carried interest is built around the team and the fund’s strategy. The first distribution reaches the managers without destructive tax. The economics for which you are launching the fund are preserved — and they hold on the second fund, and the third.