Upcoming Deadline for Form SHL (Holdings of U.S. Fund Interests by Non-U.S. Persons)
The U.S. Treasury Department is in the process of conducting its five-year benchmark survey of foreign ownership of U.S. securities as of June 28, 2024. Persons who are required to report, which may include U.S. private funds with significant non-U.S. investors, must file Form SHL with the Federal Reserve Bank of New York by August 30, 2024.
Form SHL is required to be filed by: (i) persons who are specifically directed by the Federal Reserve Bank of New York to file; (ii) U.S.-resident issuers that, together with their respective U.S. subsidiaries and affiliates, have securities with a fair market value of $200 million or more (as of June 28, 2024) owned directly by non-U.S. persons; and (iii) U.S.-resident custodians. Typically, private fund sponsors should aggregate the fair market values of the limited partner interests in each of their managed U.S. vehicles held by non-U.S. persons (including non-U.S. feeder funds) when determining if the $200 million threshold is reached.
Copies of Form SHL and its instructions are available at the U.S. Treasury Department website.
If you have any questions about the matters addressed in this Kirkland AIM, please contact the following Kirkland attorneys or your regular Kirkland contact.
