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Offshore Hedge Funds
- Taxation of U.S. Shareholders.
The U.S. tax rules applicable to
shareholders of offshore investment funds (for tax purposes, passive
foreign investment companies, or "PFICs") are complex and a trap for the
unwary. Our firm has considerable experience in advising investors
and fund managers on PFIC tax issues.
Read more about
the PFIC tax rules.
Modular Offshore
Structure. For
persons who desire a basic tax-neutral offshore asset protection and
investment vehicle, our firm has developed a flexible, modular offshore
asset protection structure based around a Nevis LLC. We have nicknamed
it the MOST - the Modular Offshore Structure. This structure is
particularly well-suited to hold and protect cash, marketable
securities, closely held business interests, receivables, and other
personal property interests.
Read more about
the MOST.
Series LLCs.
The LLC Acts of Delaware, Illinois, Iowa, Nevada, Oklahoma, Tennessee
and Utah
provide for the creation of separate “series” within an LLC whose debts
and other liabilities are enforceable against that series alone.
This allows for the creation of separate protected “cells” within one
limited liability “container” without the need to create separate
entities, thus avoiding certain inefficiencies associated with multiple
related entities. Our firm has advised on and assisted with dozens of
series LLC formations.
Read more about series LLCs.
St. Kitts & Nevis
Citizenship by Investment.
St. Kitts & Nevis is one of only two countries which offer immediate
citizenship to persons who make certain approved investments. Our firm
is very familiar with these programs and has extensive experience.
Read more
about economic citizenship.
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