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SEC Offshore Alert The SEC's 134-page report--The Implications of the Growth of Hedge Funds--presents the current status of the hedge fund industry as well as a number of recommendations related to regulation of the hedge fund industry. The web content authored by veteran hedge fund attorney Hannah Terhune, JD, LLM (Taxation)--when she was the Chief (and only) Attorney at GreenCompany.com and at GreenTraderLaw.com--on offshore hedge funds was cited on page 10 of the Report as providing information the SEC Staff found to be valuable in its understanding of the hedge fund industry. Almost all of the other 300+ footnotes were to legal cases, results of the SEC-sponsored hedge fund roundtable, and FINRA/NYSE. You will see from our web site that we supply more information about hedge funds than most books on the subject. It's great to see that Hannah Terhune's expertise is appreciated by the SEC! This is quite a coup for Hannah, and provides one more piece of evidence as to how she can help you.
Why Start an Offshore Hedge Fund? The number of offshore hedge funds continues to increase in numbers. The term "offshore" means not in your home country and the term does not refer to any one country in particular. Hedge funds are set up offshore usually for tax or regulatory reasons. Hedge fund managers should consider setting up an offshore hedge fund if they expect to have investors from other countries or if their home country's laws are not geared toward the hedge fund industry. With a handful of exceptions, most countries have high territorial and jurisdictional taxes. Why would someone not from your home country want exposure to your home country's tax laws? U.S. based hedge fund managers expecting U.S. tax-exempt investors (i.e., retirement accounts, pension funds, etc.) should consider setting up an offshore hedge fund if the use of margin trading is required to execute the hedge fund's trading program.
Hedge Fund Countries If the major consideration for establishing an offshore hedge fund is tax efficiency, the arrangement of the hedge fund structure and the choice of offshore country are important. The majority of the hedge funds are established in low or zero tax jurisdictions (i.e., tax havens). This means that there is no corporate level tax on hedge fund profits. Since most hedge funds are set up as corporations and rarely declare and pay dividends to shareholders, investors (i.e., shareholders) do not have dividend income to declare for tax purposes in their home country.
For a new hedge fund manager who is a small operator (i.e., the basement startup) and for whom the extra costs are a major burden, the best location to launch an offshore hedge fund is the United States, the British Virgin Islands, the Bahamas, Singapore, the Seychelles, or the Cayman Islands. These countries have favorable hedge fund and tax laws that allow hedge funds to start out as unregulated funds (private two share class companies) with the option to "upgrade" to a licensed (i.e., fully regulated) hedge fund.
It is not necessary to set up a licensed, fully-regulated hedge fund. In fact, for smaller operations, it is better to set up a hedge fund structure that allows it to operate as an unregulated hedge fund. Setting up a licensed, fully-regulated hedge fund takes more time and money. In our experience and in terms of hedge fund marketing optics, the two best countries to set up an unregulated hedge fund are the United States and the British Virgin Islands.
Why the British Virgin Islands? The British Virgin Islands (BVI) is an attractive and affordable country for hedge funds. The BVI government created a framework that is rigorous in terms of anti-money laundering and know-your-customer requirements while remaining very business oriented (i.e., practical). The BVI offers a suitable level of regulation for private, professional, and public funds combined with flexibility and offer great value for the money spent. It's considerably less expensive to establish a regulated hedge fund in the BVI than comparable countries such as the Cayman Islands, Bermuda and the Bahamas.
BVI Incubator Hedge Fund Regime We particularly recommend the British Virgin Island (BVI) incubator hedge fund for start-up fund managers. This is a very unique hedge fund option not available in most other countries. Learn More About Incubator Hedge Funds A BVI incubator hedge fund -- a "closed-ended" fund -- is not regulated by the BVI Financial Services Commission (FSC). It is a fully legal hedge fund structure with Its authorization is contained within the Memorandum & Articles of Association (M&A) of a BVI multiple share class entity.
The BVI incubator hedge is structured in the same manner as a regulated hedge fund but an investor does not have an absolute right to redeem shares on demand. The M&A is drafted to limit the right of investors to redeem shares on demand. Instead, the right to redeem is left to the sole discretion of the hedge fund's director. If and when the BVI incubator hedge fund is converted to a BVI regulated hedge fund, its M&A is amended to include a right to redeem on demand for the shareholders.
Do not let the words "closed-ended" confuse you. The BVI incubator hedge fund -- even though called "closed-ended" -- can accept investor subscriptions on a continuous basis and is identical to private, professional, and public funds in that regard. The BVI closed-ended fund structure can be upgraded to either a private, professional or public fund (i.e., fully-licensed fund) in the future, if desired. Of these categories, a public fund is the best option for a retail hedge fund; however it is the most expensive type of fund to establish (and therefore out of reach for most smaller, start up hedge funds).
Sponsors and fund managers considering a BVI fund may choose to structure the fund as one of the following: a BVI business company, a limited partnership or a unit trust. The majority of BVI investment funds are established as companies limited by shares under the Business Companies Act (2004). Limited partnerships are also a common form of investment fund, while unit trusts are relatively rare.
Cayman Islands The reason why we do not prefer the Cayman Islands (for small hedge funds) is because it takes more time and money to set up a hedge fund there. Most of our clients are in a rush to set up their offshore fund once they decide to pull the trigger and start the project. Another reason is that the country is in a bit of regulatory turmoil--read this link. If you want to set up your fund there, we will be pleased to help you.
The Cayman Islands allows for four (4) types of hedge funds, two (2) of which are important to hedge fund managers starting a small offshore fund. Those types of hedge funds are the Category 4(3) fund and the Category 4(4) Fund. While not much is required in the way of due diligence by the Cayman Islands Monetary Authority (CIMA) during the incorporation process, it is very slow. Even a small hedge fund has to be registered with CIMA under the Mutual Funds Law. This means engaging all service providers (i.e., the auditor, the administrator, the custodian, etc.) for the hedge fund very early on in the process. CIMA has to be notified of any subsequent changes. The Category 4(4) fund (i.e., which is used for incubator hedge funds) authorizes one share class and all investors in the fund can vote. The fact that all investors can vote is not typical of a hedge fund structure and also presents a potential control issue to hedge fund management. This problem does not arise in a U.S. or BVI incubator hedge fund. The "Cayman issue" does appear in many other countries. For this reason, the two best countries to set up a smaller hedge fund are the United States and the British Virgin Islands.
Why the United States? Even if you are based in another country, consider forming a U.S. hedge fund. The United States offers easy, low-cost access to the legal, tax, accounting, retail and institutional brokerage services, and regulatory services needed by a hedge fund sponsor to organize a hedge fund. Despite what some investors think about the purported negativity surrounding the United States, many more investors continue to establish U.S. based hedge funds because of the minimal expenses associated with starting a U.S. hedge fund.
Hedge fund sponsors (i.e., the organizer(s) of the hedge fund) based outside the United States are usually surprised and delighted to learn about the “light touch” of U.S. regulation and low costs associated with forming a U.S. hedge fund. The United States is a tax haven for foreigners. Learn More About U.S. Incubator Hedge Funds and Starting a U.S. Hedge Fund The best news of all is that U.S. hedge funds can be marketed just like retail funds as a result of a recent law change. There is no longer a ban on advertising. Learn More About Raising Capital for a Hedge Fund This puts the United States at the top of the list as one of the best countries for hedge funds.
Why Consider a Master-Feeder Structure Confusing to some is the use of onshore and offshore feeder funds in a master-feeder hedge fund structure. The master-feeder structure allows a hedge fund manager to manage money for a broad spectrum of investors. The master fund, structured in most cases as an offshore corporation, engages in all trading activity on behalf of the investors in the feeder funds.
Typically, investors do not invest directly into the master fund. A hedge fund manager can pool investor money into a home country feeder fund and "feed" monies into the offshore master fund. If offshore investors exists, an offshore feeder fund can be established for them in their home country or in another country. Trading gains and losses are allocated to the feeder funds based on the percentage assets under management in each feeder fund.
Many variations of the foregoing structure exists and the variations, at least in the United States, are driven by the pursuit of the U.S. tax lawyer's Holy Grail: preservation of the low tax rate on the carried interest. The U.S. Holy Grail consists of (1) preserving the tax status of the "carried interest" that exists from the payment of performance allocations and/or (2) creating a "carried interest" by converting a performance fee to a performance allocation for U.S. tax purposes. This is the purpose of the mini-master fund structure (see below).
U.S. Feeder Hedge Fund with Offshore Master Hedge Fund If you are a U.S. based fund manager, consider setting up an offshore fund if you manage money for foreign and/or U.S. tax-exempt individuals and businesses. Under U.S. income tax laws, a tax-exempt organization (such as an ERISA plan, a foundation, or an endowment) engaging in an investment strategy that involves borrowing money is liable for a tax on "unrelated business taxable income" (UBTI), notwithstanding its tax-exempt status. The UBTI tax can be avoided by the tax-exempt entity by investing in offshore hedge funds.
The master feed hedge fund structure typically includes a U.S. limited partnership (unless multiple share classes are needed; in that case, the hedge fund is a limited liability company) as the U.S. feeder hedge fund for U.S. taxable investors and a foreign corporation as the offshore feeder hedge fund for foreign investors and U.S. tax-exempt investors. A master hedge fund is formed offshore as well. The master hedge fund, structured as an offshore corporation, should file a Form 8832 with the Internal Revenue Service (e.g., a check-the-box election allowing the master hedge fund to be treated as partnership for U.S. tax purposes) before engaging in trading activity on behalf of the feeder hedge funds.
Some investment managers try to skip the offshore master fund to save money and attempt to use the offshore feeder hedge fund as the master hedge fund. However, If U.S. taxable investors invest in or effectively control the offshore hedge fund, complex U.S. tax rules applicable to controlled foreign corporations, foreign personal holding companies, or passive foreign investment companies (PFIC) may become problematic for the U.S. investors.
U.S. Investors and Offshore Funds Offshore hedge funds are generally organized as corporations for marketing, tax, and legal reasons. Less frequently, offshore hedge funds will elect to be treated as a partnership for U.S. tax purposes to attract U.S. individual investors as well as participate in master-feeder fund arrangements. When U.S. investors are involved, a master-feeder structure typically includes (in addition to the master fund) a U.S. limited partnership (LP) or limited liability company (LLC) as the feeder fund for U.S. taxable investors and a foreign corporation as the offshore feeder for foreign investors and U.S. tax-exempt investors. If an offshore feeder corporate fund is set up for U.S. tax-exempt investors (i.e, a UBTI blocker), it them makes sense to elect on IRS Form 8832 to have the master fund taxed as a partnership for U.S. tax purposes. This election will simplify tax issues for investors in the U.S. feeder fund.
U.S. Tax Issues for Offshore Funds Whenever, U.S. taxable investors invest in or control an offshore hedge fund, some complex U.S. tax issues are in play. Key U.S. tax issues encountered by any hedge fund with U.S. taxable investors include: passive foreign investment company (PFIC) rules, controlled foreign corporation (CFC) rules, U.S. tax reporting rules, effectively connected income (ECI) rules, withholding tax rules and income tax treaties; and unrelated business taxable income (UBTI) rules. However, these rules are manageable when knowledgeable tax advisors are on board.
PFIC rules work as an anti-tax deferral mechanism. A offshore hedge fund taxed as a corporation is classified as a PFIC when either (i) at least 75% of its gross income is “passive income;” or (ii) at least 50% of the average value of its gross assets are “passive.” These rules can just creep in. For example, a U.S. taxable investor in a U.S. fund of funds (FOF) may have tax issues if the U.S. FOF invests in a PFIC. That is because the investor is treated for U.S. tax purposes as investing directly in the foreign fund. If the foreign fund also invests in a foreign fund, it's treated as a subsidiary PFIC and the U.S. taxable investor is treated as owning a pro rata share of the subsidiary PFIC. The upshot of all this is that taxable gain from sale of the PFIC interest is converted from capital gain to ordinary income.
Making of a Qualified Electing Fund can avoid these tax issues but a U.S. taxable investor is required to include in income annually its pro-rate share of the PFIC's annual income and gains. The QEF election also triggers an annual income inclusion for the U.S. taxable investor even though there is no actual cash distribution (i.e., phantom income).
CFC rules work as anti-deferral mechanisms. CFCs require greater than 50% ownership by U.S. shareholders (i.e., a U.S. FOF investor in an offshore fund taxed as a corporation is a shareholder) each owning more than 10% of the voting stock of the foreign fund. This is not a common scenario. However if the U.S. FOF or an underlying hedge fund owns a CFC then U.S. taxable investors include in income a ratable share of the investment income of the underlying CFC. Gain from sale of the CFC interest is converted from capital gain to ordinary income (usually in part). If an underlying investment is both a CFC and a PFIC, the CFC rules apply if the U.S. FOF owns more than 10% of the CFC.
U.S. Tax Reporting. In any year that a U.S. FOF has a 10% percent or greater interest in a foreign fund, either directly or indirectly through an underlying hedge fund that is a partnership for U.S. tax purposes, IRS form 5471 is completed for that year. Much information is needed from the foreign fund to complete the Form 5471.
ECI. Foreign investors and foreign funds are taxed on income that is effectively connected to the conduct of a U.S. trade or business (ECI). An offshore Fund is subject to U.S. tax if it is engaged in a U.S. business. An offshore fund that invests in a U.S. partnership (i.e., a U.S. fund or FOF) is treated as engaged in a U.S. Business. An offshore fund is then taxed as the regular corporate tax rate on its allocable share of U.S. income. In addition, the 30% branch profits tax applies, subject to a reduced tax treaty rate, if applicable. An offshore fund engaged in a U.S. Business, is required to file U.S. federal income tax returns and failure to file a U.S. tax return within 18 months of its due date causes the offshore fund to be taxed on its gross income as U.S. ECI without any deductions allowed. Although investing in or trading U.S. stocks, securities and commodities is not considered to be the conduct of a U.S. business, certain activities or investments by an offshore hedge fund formed as a partnership may give rise to it being engaged in a U.S. business, including: investment in a U.S. pass-through entity (e.g. a U.S. LLC) that is engaged in an active operating U.S.business, loan origination activities, distressed debt investment, investments in U.S. real property interests and being a dealer in securities.
Mini-Master Offshore Fund In this structure a offshore master hedge fund is formed and elects to be treated as a partnership for U.S. tax purposes. A stand-alone (i.e., feeder fund) U.S. hedge fund funnels its cash into the offshore master hedge fund. All trading takes place in the offshore master hedge fund, which is more efficient. The offshore master hedge fund is structured as a limited partnership and its general partner is itself another partnership. The general partner is allocated the performance allocation and receives the allocation of performance fee. This allows the hedge fund manager to receive what would normally be a currently-taxed performance fee a partnership allocation in the form of tax-favored, long-term capital gains and qualified dividends. This allows the hedge fund manager to defer current taxation of the entire performance fee (as a performance allocation typically include an element of unrealized gain).
A Simple IBC is not a BVI Hedge Fund If the BVI hedge fund is set up as a BVI business company, it is not a simple IBC. It does not require BVI directors or the filing of audited financial statements. A separate investment management company, custodian, administrator or auditor is not required. However, having those arrangements in place will help you sell shares in your hedge fund. In a BVI incubator fund, it is possible to charge performance, management and other fees. Learn More About Performance Fees There are no restrictions on marketing. In addition, when offering documents are prepared, it functions just like any other hedge fund in the world.
The BVI incubator hedge fund can be offered with or without hedge fund offering documents. It is very important that the restricted redemption rights of investors are fully disclosed in the fund's offering documents. Learn More About Offering Documents Such restricted redemption rights may cause some prospective investors to be hesitant to invest in the fund. However, when the closed ended hedge fund is properly marketed by word of mouth to personal and business associates, friends and relatives, the restrictive redemption rights should not pose a problem. Learn More About Hedge Fund Marketing
There are no restrictions with respect to raising capital for the BVI incubator hedge fund and marketing efforts should be focused on the hedge fund's performance. Learn More About Hedge Fund Performance Reports The word "fund" cannot be used in the company name, as this is right is reserved for fully regulated funds in the BVI. In the United States, you can use the word "fund" in the company name.
BVI Licensed Hedge Funds The BVI is a good country to set up not only an incubator hedge fund but also a fully regulated hedge fund. The BVI investment funds industry is regulated by the Investment Business Division of the Financial Services Commission (FSC). The FSC is the BVI's financial services regulator and the Investment Business Division of the FSC is responsible for the regulation of the BVI's funds industry. The industry is primarily governed by the Securities and Investment Business Act 2010 (Act). Under Part III of the Act, and the Mutual Fund Regulations (2010), regulated funds are categorized as either private funds, professional funds, or public funds. However, not all funds are subject to the Act, as the Act regulates only open-ended funds (whose equity interests are redeemable at the option of the investor). Consequently, closed-ended funds (whose equity interests are not redeemable at the option of the investor) are not subject to specific regulation in the BVI. The redemption feature represents the key distinction between closed-ended, private, professional and public funds.
BVI Private Funds A private fund is restricted to either having no more than 50 investors, or only issuing invitations to subscribe for or purchase fund interests on a private basis. In practice, however, BVI private funds have accepted up to 300 investors. BVI private funds must be recognized by the FSC before they can conduct business.
BVI Professional Funds A BVI professional fund is a fund in which the shares are made available only to professional investors, and the minimum initial investment by each such investor (other than exempted investors) is not less than $100,000 (or other currency equivalent).
BVI Private and Professional Fund Requirements BVI Private and Professional funds recognized under the Securities and Investment Business Act, 2010 (“SIBA”) are generally required to appoint an auditor and to file their audited financial statements with the Commission not more than six months after the end of each financial year. SIBA requires that a fund wishing to be recognized or registered must appoint the following functionaries: an investment manager, an administrator, a custodian, and an auditor. However, private or professional funds may apply for an exemption from appointing an investment manager, custodian, or auditor. In considering an application for recognition or registration, SIBA requires that the investment manager, administrator and/or custodian of a BVI mutual fund satisfy the FSC’s fit and proper criteria.
The FSC has designated the following countries as recognized jurisdictions: Argentina, Australia, Bahamas, Bermuda, Belgium, Brazil, Canada, Cayman Islands, Chile, China, Denmark, Finland, France, Germany, Gibraltar, Greece, Guernsey, Hong Kong, Ireland, Isle of Man, Italy, Japan, Jersey, Luxembourg, Malta, Mexico, Netherlands, Netherlands Antilles, New Zealand, Norway, Panama, Portugal, Singapore, Spain, South Africa, Sweden, Switzerland, United Kingdom, and the United States.
Private and Professional funds recognized under the Securities and Investment Business Act, 2010 (SIBA) are generally required to appoint an auditor and to file their audited financial statements with the Commission not more than six months after the end of each financial year. The fees payable by BVI funds to the FSC are lower than those in other offshore jurisdictions. A private or professional fund must pay a $700 application fee, and an annual fee of $1,000. A public fund must pay $1,000, on application for registration, and an annual fee of $1,500. However, no fees are due and payable to the FSC for a closed-ended fund.
Deferral of Home Country Income Tax on Performance and Management Fees A hedge fund manager of an offshore hedge fund manager must make sure that the investment management agreement between the fund and the investment manager is drafted correctly to allow for tax deferral (tougher in the United States since 2008, but possible) on management and performance fees. The use of properly prepared investment management agreements, offering documents, constitutional documents and outside (i.e., third party) directors, allow hedge fund managers to defer tax on performance and management fees. A tax saving bonus results from the fact that deferred fees and earnings on the fees compound tax free in the offshore hedge fund.
Prior to 2008, U.S. hedge fund managers routinely deferred receipt of performance fees from managing offshore hedge funds. This deferral meant that the performance fee was not taxed currently. A U.S. law change in 2008 made it more difficult to defer performance fees. As a result, some hedge fund managers redrafted investment management agreements to pass muster under the new law. Other restructured existing operations slightly to change the U.S. tax characterization of the offshore performance fee. New hedge fund managers may consider the following structure.
UBTI and Using Blocker Entities U.S. tax-exempt investors are taxed on the receipt of any unrelated business taxable income (UBTI). UBTI includes income from a trade or business regularly carried on by a tax-exempt entity and generally does not include dividends, interest or capital gains. Blockers are entities set as corporations that are placed in a structure in order to change the character of the underlying income or assets to obtain tax results that may otherwise be unavailable.
The use of blocker companies is common. Hedge funds use blockers to prevent U.S. tax-exempt investors from recognizing UBTI and to prevent foreign investors from recognizing taxable U.S. trade or business effectively connected income (ECI). U.S. feeder hedge funds use foreign corporations as blockers to invest in a hedge fund or so that the hedge fund may invest in portfolio companies.
U.S. Law Favors Offshore Hedge Funds Despite the U.S. government's continuing crackdown on illegal offshore accounts, offshore hedge funds remain preferred by upper-income U.S. investors when faced with a choice between an offshore hedge fund and its U.S. onshore version. For hedge funds that use leverage, an offshore fund is preferable because of its tax advantages. For U.S. investors, the tax savings flow from the opportunity to be taxed on net (and not gross) income and the chance to deduct state-tax and other itemized deductions thwarted by the alternative minimum tax. In addition, investing in the offshore fund allows a U.S. investor to avoid some or all of the 3.8% Medicare tax on investment income (taking effect in 2013). Moving assets abroad is especially useful to U.S. investors living in high tax states.
The U.S. withholding tax system operates on a self-certification basis (through the provision of Form W-8), which permits the U.S. entity that has the withholding obligation (i.e. the withholding agent) to distribute the item of income without withholding of tax if it has received the applicable W-8 form. In a tiered entity structure involving U.S. and foreign organizations, the obligation to withhold U.S. income tax on distributable income is generally imposed on the last U.S. entity in the distribution chain.
As a foreign pass-through entity, the investment manager of an offshore master hedge fund should provide Form W-8IMY (Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or Certain U.S. Branches for United States Tax Withholding) to its paying agents (along with Form W-8BEN if there is an offshore feeder hedge fund and a Form W-9 for the U.S. feeder hedge fund) so that the paying agents (i.e., brokers and banks) know how much of the underlying ownership of the offshore master hedge fund is foreign to ensure proper U.S. tax withholding on U.S. dividends allocable to the offshore feeder hedge fund. The Form W-8IMY should be updated often as offshore ownership of the offshore master hedge fund will vary as withdrawals and contributions take place (due to shareholder changes in the domestic and offshore feeder funds).
Depending on the level of ownership (and other factors) a reporting party may have to provide detailed balance sheet, income statements and other information regarding related party transactions. A Form 8865 may have to be filed by a U.S. feeder fund and possibly even a Form 90-22.1 (Report of Foreign Bank and Financial Accounts) as the offshore master hedge fund is considered a financial account. Learn More About Offshore Hedge Fund Tax Compliance IRS Form 8865, Return of U.S. Persons with Respect to Certain Foreign Partnerships, is the mechanism for reporting contributions and certain levels of ownership, or changes in ownership, of foreign partnerships.
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