IFI Global Survey Identifies Trends in Offshore Domiciliation and Fund Structuring Among U.S. Managers

Offshore funds are a key component of most PE fund structures, providing non‑U.S. investors the opportunity to invest without becoming subject to U.S. tax authorities and providing U.S tax-exempt investors a shield against unrelated business taxable income. Although the Cayman Islands continues to be the most popular jurisdiction for offshore funds, other locations are becoming more popular as managers look for investors in various geographies. Beyond domiciles, managers hoping to market to European investors also need to consider how they will meet regulatory standards, such as by operating through a third-party management company or by performing functions in-house. IFI Global recently hosted a webinar to discuss the results of its survey (Survey) of U.S. alternative investment managers and lawyers on overseas fund structuring issues, trends and forthcoming developments of note. The program was hosted by IFI Global CEO Simon Osborn and featured Lynne M. Carreiro, senior vice president at Greyline Partners; Miles J. Edwards, GC and CCO at Bruderman Brothers; Debra Franzese, partner at Seward & Kissel; Wouter Plantenga, ICS head of group client services at JTC; and Cyril Schopfer, director of client coverage at RBC Investor & Treasury Services. This article highlights the key insights and relevant takeaways from the Survey and the panelists’ corresponding discussion. See “The New E.U. Cross‑Border Distribution of Funds Rules” (Aug. 31, 2021).

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