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Alternative Structures for Funds of Hedge Funds  


Author:  Eric J. Byrnes.; Kenneth M. Kess.


Source: Volume 23, Number 02, 2009 , pp.19-28(10)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

A fund of hedge funds product can take many forms—registered or unregistered, partnership or RIC—and may invest onshore or offshore. While sharing certain tax advantages and disadvantages, each structure and investment choice has its own distinct tax attributes that must be weighed carefully before one makes a decision about which form to choose, and how to invest.

Keywords: Hedge Funds; Diversification Strategies; Controlled Foreign Corporations; CFC; Regulated Investment Companies; RIC; Qualified Publicly Traded Partnerships; QPTP; FOHF

Affiliations:  1: Deloitte Tax LLP; 2: Deloitte Tax LLP.

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