Bilaterally negotiated loans generate income effectively connected with a U.S. trade or business (ECI). For private credit funds with non‑U.S. or tax-exempt investors, the traditional structural answers – e.g., leveraged blockers and season-and-sell programs – surrender returns to tax leakage. An Irish treaty fund can eliminate that leakage outright for managers that satisfy the treaty’s tests, and the revamped European long-term investment fund (ELTIF) regime is opening retail capital in Europe just as sponsors most need to widen their fundraising nets. Those opportunities anchored a webinar moderated by Simmons & Simmons partner James McKnight, which featured Seward & Kissell partner Joseph M. Morrissey, Simmons & Simmons partner Martin Phelan and EisnerAmper partner Irina Kimelfeld. This article examines the panelists’ analysis of the ECI problem in loan origination and the tax leakages in certain structures; the ownership, base erosion and permanent establishment tests for accessing Ireland’s tax treaty with the U.S.; and the attraction of using an ELTIF to access European investors under the recast Alternative Investment Fund Managers Directive. See “European PE Fund Domiciles: How Does the U.K. Compare?” (Apr. 30, 2026); and “A U.S. Fund Sponsor’s Perspective on AIFMD 2.0” (Sep. 4, 2025).