May 11, 2021

Reinsurance: Considerations for Hedge Fund Managers evaluating forming reinsurance vehicles in the Cayman Islands

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By Tim Frawley and Karey B. Dearden, Maples and Calder; Ernst & Young From the Hedge Fund Law Report Volume 7, Number 33 There has been much talk recently about the formation of reinsurance companies by hedge fund managers. Indeed, in the Cayman Islands (Cayman), there has been significant increase of interest in the establishment […]

IRS applies the §956 indirect investment rule to a partnership loan [Cayman Islands CFC]

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By Lowell D. Yoder, Esq. McDermott Will & Emery, Chicago, IL From Newly Enhanced! Premier International Tax Library Monday, October 6, 2014 – The IRS recently issued a Chief Counsel Advice (CCA) applying the §956 indirect investment rule to a loan made by a foreign partnership to one of its CFC partners, which used the […]