Investing in US private credit
Published Date: 26 Aug 2025
This article explores the growing interest of Australian institutional investors—particularly superannuation funds—in the US private credit market. It outlines the structural shift from traditional bank lending to private credit due to regulatory constraints and investor demand for higher yields. The article also considers key US tax considerations and compares common fund structures—such as leveraged blockers, treaty-based entities, and season-and-sell models—highlighting their tax impacts. It discusses challenges unique to Australian investors, including foreign hybrid rules, foreign income tax offsets and compliance burdens. Finally, the article notes the evolving US tax policy landscape under the Trump administration and active IRS campaigns, which further complicate the investment environment, underscoring the need for careful consideration of proposed US private credit investment structures.
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Details
- Published By: Peter Oliver CTA, Vanessa Kasbekar
- Published On:26 Aug 2025
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