News & Analysis as of

Investors Offshore Funds

Proskauer Rose LLP

Proskauer's Hedge Start: Key Structuring Issues

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A key initial decision for a manager launching a new hedge fund is to decide between: A “master-feeder” fund structure: In a typical “master-feeder” structure, an onshore “feeder” fund and an offshore “feeder” fund both...more

Proskauer Rose LLP

Proskauer’s Hedge Start: Key Tax Issues

Proskauer Rose LLP on

Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more

Fox Rothschild LLP

Tax Court’s Decision on YA Global Investments Has Implications for Offshore Entities

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The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more

Conyers

ケイマン諸島プライベートエクイティ/ベンチャーキャピタル/不動産ファンドの設立

Conyers on

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

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Seward & Kissel LLP

Building a Scalable Hedge Fund Business

Seward & Kissel LLP on

As new portfolio managers enter the hedge fund space with dreams of running billions of dollars in a traditional US/offshore master-feeder structure, many of these managers are encountering the asset raising headwinds that...more

Conyers

BVI Hybrid Funds

Conyers on

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

Conyers

BVI Multi-Class Funds

Conyers on

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

K&L Gates LLP

Hong Kong’s New Unified Tax Exemption for Onshore and Offshore Privately-Offered Funds

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Hong Kong’s Inland Revenue (Profits Tax Exemption for Funds) (Amendment) Bill 2018 (the “Bill”), which will take effect on 1 April 2019, represents a significant development for Hong Kong’s privately-offered funds industry by...more

Patterson Belknap Webb & Tyler LLP

Chapter 15: Court Permits Foreign Debtors to Access and Receive Funds in U.S. Account

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

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

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• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Morgan Lewis

Japan FSA Finalizes Amendments to the Article 63 Exemption

Morgan Lewis on

Final text of the Regulations with respect to the Amendments promulgated has been released as well as the Response to the public comments....more

K&L Gates LLP

Amendments to the Calculation Method for FDI Positions

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Before offshore funds may be publicly offered and distributed in Taiwan, they must be registered with the Securities and Futures Bureau of the Financial Supervisory Commission (SFB). In order to be registered with the SFB,...more

Dechert LLP

Financial Services Quarterly Report - Third Quarter 2013: Recent Developments in the Hong Kong Funds Industry

Dechert LLP on

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

Carlton Fields

Concurrent EB-5 Offerings In The United States And Abroad

Carlton Fields on

Until recently, U.S. offerors and others had to make offerings of EB-5 project investments solely offshore in order to benefit from Regulation S, an exclusion from registration requirements. The offerors had to exclude...more

Dechert LLP

Financial Services Tax – UK Update from Dechert’s Tax Group: Rule Changes Yield Mixed Blessings for UK Investors in Offshore Funds

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UK investors in closely held offshore funds can be directly liable for tax if the fund makes a gain on an underlying asset even if the gain is reinvested by the fund and not distributed to the investor. There is also the...more

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