Foreign limited partners/syndications

[Michinori Kaneko]

Hi,

has anyone done a syndication deals with foreign partners?  I'm thinking about doing a syndicated deal with families and friends I have in Japan down the line, but the whole over the sea issue may add additional layer of complexity. What is the best legal entity to form for this? How do we deal with taxes on pass through income for these partners? Would there be consequence at the entity level (even though the entity is pass through, would government in Japan be able to tax at the entity level if the partners lived in japan)?  Any other considerations I am not thinking about? Any inputs/suggestions would be helpful.  Thank you