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ファンドの 投資家 がファンドに対して償還 請求権を有するオープンエンド型ファンドは、 流動性 のある 資産に投資するヘッジファンド等ファンド に適している一方、プライベートエクイティ、ベンチャーキャピタル、不動産等の非流動資産に投資するファンドは、投資が実現するまでにより多くの時間を必要とし、クローズドエンド型ストラクチャーが適しています。...more
In this series of articles we consider two of the more common requests we see in terms of fund structuring options: Multi-Class Funds, and Hybrid Funds. This second article in the series will consider Hybrid Funds....more
In this series of articles we consider two of the more common requests we see in terms of fund structuring options: Multi-Class Funds, and Hybrid Funds. This first article in the series will consider Multi-Class Funds. Hybrid...more
The introduction of economic substance requirements in offshore jurisdictions has sharpened the impetus for investment fund managers to establish a physical office where their funds are incorporated. Here are six good reasons...more
A court in New York has allowed offshore debtors to take control of an investment account in the U.S. over the objection of a shareholder. At stake was the court’s discretion to permit chapter 15 debtors to access the funds...more
The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more
This year’s Autumn Statement delivered by the Chancellor of the Exchequer in Parliament on 5 December 2013, and the subsequent draft Finance Bill and H.M. Revenue & Customs (HMRC) and H.M. Treasury press releases of 10...more
The Hong Kong Government has been keen to demonstrate its willingness to evolve and focus its efforts on the overall growth of the Hong Kong financial services industry. Recent proposals to make fund-friendly changes to Hong...more
Offshore Master with U.S. and Offshore Feeders - This is the third in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect...more
This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more
U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more