The Tax Guide to Offshore Lending

116 Pages Posted: 3 Nov 2020

Date Written: October 5, 2020


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

Keywords: tax, loan origination, offshore fund

JEL Classification: H20

Suggested Citation

Miller, David S., The Tax Guide to Offshore Lending (October 5, 2020). Available at SSRN: or

David S. Miller (Contact Author)

Proskauer Rose LLP ( email )

Eleven Times Square
New York, NY 10036-8299
United States

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