A developing theme in recent years has been the extent to which current fund structures will continue to achieve the aim of minimizing tax leakage. This has largely emanated from coordinated action of the Organisation for Economic Co‑Operation and Development and E.U. member states to tackle and prevent perceived tax avoidance and treaty abuse. As a result, it is now important to carefully consider not only whether the economic substance of a fund structure can withstand scrutiny from a tax perspective, but also whether it will continue to minimize tax leakage in the future. In a guest article, Will Smith and Caleb McConnell, partner and associate, respectively, at Sidley Austin, address a number of the important changes to the international tax framework that have affected the tax planning involved in fund structuring. In addition, the article provides practical points to consider for a European fund structure in light of these international tax changes. For analysis of other tax issues, see “Sidley Panel Discusses Operational and Tax Challenges of Hybrid Funds” (Nov. 5, 2019); and “PE Real Estate Funds: Unique Fund Terms and Notable Tax Items (Part Three of Three)” (Sep. 3, 2019).