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Private Real Estate Fund

We help our client to engineer real estate fund registered in British Virgin island, that invest through a domestic Limited Liability Company incorporated in Delaware. 

 

The foreign investor invest in the Delaware company receiving shares backed by the real estate of the fund, effectively creating a loan that avoiding FIRPTA and any tax liabilities.

 

A master-feeder structure consists of a domestic feeder fund and an offshore feeder fund (in a tax-free jurisdiction) that feed into a single offshore master fund, where all the trading activity of the fund takes place. 

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A leveraged domestic blocker is a US corporation (usually set up in Delaware) that is capitalized with a mix of loans and equity. 

The aim of the leveraged domestic blocker is to shield offshore Investors fro the US-tax filing obligations that FIRPTA imposes, while reducing non-US investors’ effective rate on the real estate fund investment. 

Past performance is not a guide to future performance and may not be repeated. The value of investments and the income from them may go down as well as up and investors may not get back the amounts originally invested. All investments involve risks including the risk of possible loss of principal.

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