美国拟对全球主权财富基金“征税”，或引发新一轮大撤退？

Core Viewpoint - The proposed reform by U.S. authorities may require sovereign wealth funds to pay taxes on their investments in the U.S., impacting major investors in the private equity sector [2][3]. Group 1: Proposed Tax Reforms - The IRS plans to amend the tax exemption rules for sovereign wealth funds and certain public pension funds under Section 892 of the Internal Revenue Code, expanding the definition of "commercial activities" [2][3]. - Activities that may trigger tax obligations for sovereign wealth funds include direct lending to companies and involvement in debt restructuring [2][6]. Group 2: Impact on Investment Strategies - The proposed changes could affect how sovereign wealth funds invest in private equity, particularly regarding their ownership stakes in portfolio companies [6][7]. - The definition of "control" will be broadened, potentially leading to tax liabilities for funds that previously enjoyed tax-exempt status [6][7]. Group 3: Market Context and Trends - Global sovereign wealth funds' private credit investments are projected to reach $550 billion by 2025, with direct private equity investments in the U.S. having more than doubled to $73 billion last year [3]. - Approximately one-quarter of private credit assets held by state-owned entities come from direct investments rather than through private market asset management funds [6].