The Resource Offshore hedge fund investment vehicle

Offshore hedge fund investment vehicle

Label
Offshore hedge fund investment vehicle
Title
Offshore hedge fund investment vehicle
Creator
Subject
Language
eng
Summary
The recent proliferation of hedge funds and marked increase of assets under management in the hedge fund industry has gained the attention of various regulatory agencies in the US government. Hedge funds are now the staple of institutional investors, public, private and government retirement plans, as well as sovereign government funds. For several reasons, these new investors have a tendency of investing through the offshore vehicle structure of a hedge fund. This article discusses the typical operations of the offshore equivalent of a domestic hedge fund, specifically covering structure, the unrelated business taxable income (UBTI) aspects of an offshore fund as applied to tax-exempt investors, the U.S. taxpaying nature of an offshore fund or the lack of it as applied to effectively connected income (ECI) and fixed or determinable income (FDAP), and various disclosures to the IRS that an offshore fund may be subject to
Citation source
In: International tax journal. - Chicago. - Vol. 35 (2009),
http://library.link/vocab/creatorName
Ng, S
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • hedge fund
  • offshore fund
  • disclosure
Label
Offshore hedge fund investment vehicle
Instantiates
Publication
Label
Offshore hedge fund investment vehicle
Publication

Library Locations

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      52.3736660 4.9336932
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