
Vanquish
REAL ESTATE
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.


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.