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June 06, 2021 The Tax Lawyer

The Tax Guide to Offshore Lending

Vol. 74, No. 3 - Spring 2021

by David S. Miller


The Article explains the various structures that permit offshore funds with U.S. managers to originate loans without the fund or its investors being subject to any meaningful amount of U.S. tax. The Article also discusses a legislative change that would render these structures moot.

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