The Hedge Funds Weblog
Offshore Hedge Fund Launch
In HedgeCo story "Rubinstein & Rubinstein Launch Alternative Offshore Fund": Taking advantage of a tax treaty between the United States and a foreign government, Rubinstein & Rubinstein established the fund in an offshore jurisdiction, reducing taxation to 1 to 2%. In addition, private placement and foreign registration allowed the fund exemption from S.E.C. and blue sky registration.
Kenneth Rubinstein has also developed a proprietary tax strategy to allow tax-free access to offshore deferred compensation assets by hedge fund and private equity fund managers.
The strategy is particularly timely, given the recent calls by members of the United States Congress to increase taxes on the "carried interest" portion of fund managers' compensation. Rubinstein & Rubinstein's tax patent application for this strategy is currently pending before the United States Patent and Trademark Office.
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