It needn't be taxing

Tax regulation

It is axiomatic that a hedge fund or fund of hedge funds must be structured to enable not only the investment manager to prosecute successfully the fund's investment objective, policy and methodology, but also to ensure that the target investors regard the structure chosen as tax-efficient.

In this context, it has been easy to minimise the significance of also making sure the investment manager's business is structured tax-efficiently.

Offshore funds will typically be open-ended (though there

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