Download This PaperThe Tax Guide to Offshore Lending
116 Pages Posted: 3 Nov 2020
Date Written: October 5, 2020
Abstract
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: Suggested Citation
Miller, David S., The Tax Guide to Offshore Lending (October 5, 2020). Available at SSRN: https://ssrn.com/abstract=3676575 or http://dx.doi.org/10.2139/ssrn.3676575
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