Most emerging managers know they’ll need outside capital to reach viability. Fewer appreciate how central an offshore fund can be to a successful seed. Used well, an offshore structure does more than park non‑U.S. and tax‑exempt dollars—it can de‑risk a seed deal, widen your investor base, and make the economics far cleaner for both manager and seeder. This guide distills what actually works in practice: how to choose the right domicile, structure the investment, protect both parties, and avoid the tax and regulatory potholes that derail launches.
Why Offshore Matters in Seeding
Offshore funds are not just a tax gimmick; they’re the default chassis for global hedge fund capital formation. Three reasons:
- Investor compatibility. Non‑U.S. investors and U.S. tax‑exempt investors (endowments, foundations, pensions) prefer to invest through a non‑U.S. corporate “blocker” to avoid U.S. effectively connected income (ECI) and unrelated business taxable income (UBTI).
- Marketing credibility. The market expects a master‑feeder architecture. It signals you’re institutionally ready and removes friction when you start speaking with pensions, sovereigns, and global platforms.
- Flexibility for seeding economics. Offshore vehicles can hold GP or revenue‑sharing interests, warehouse early investors, and ring‑fence key terms for seeders without contaminating the flagship.
In practice, day‑one “anchor” tickets typically range from $25–$100 million for emerging managers, representing 10–30% of day‑one assets. Seeders expect clean onboarding and robust governance from the start. The offshore fund is where those expectations are met.
Core Structures You’ll Actually Use
The workhorse: Cayman master‑feeder
- U.S. feeder: Delaware LP or LLC, a pass‑through fund for U.S. taxable investors.
- Offshore feeder: Cayman (most common) exempted company feeding into the master. It serves non‑U.S. investors and U.S. tax‑exempt investors as a blocker.
- Master fund: Often a Cayman exempted limited partnership (for operational flexibility) trading the consolidated portfolio.
Why this works:
- Keeps U.S. taxable investors out of PFIC complications.
- Shields non‑U.S. and U.S. tax‑exempt investors from ECI/UBTI.
- Centralizes trading, financing, and expense allocation at the master.
When to deviate:
- If you’ll be mostly non‑U.S. and tax‑exempt for several years, a stand‑alone Cayman fund can be simpler and cheaper.
- If you’re EU‑heavy, consider an Irish QIAIF or Luxembourg RAIF master with offshore feeder, but weigh AIFMD marketing needs and ongoing costs.
Stand‑alone offshore fund
An open‑ended Cayman company or LP with no U.S. feeder. It’s appropriate when:
- The first two or three years will be >80% non‑U.S./U.S. tax‑exempt capital.
- The strategy is unlikely to generate ECI/UBTI at the fund level (vanilla trading).
- You want to avoid complexity until U.S. taxable demand arrives.
You can add a U.S. feeder later and convert to a master‑feeder with minimal tax friction if planned carefully.
Segregated portfolio companies (SPCs) and umbrellas
SPCs (Cayman) and protected cell/umbrella structures (Jersey/Guernsey/Luxembourg) allow multiple sub‑funds with legal segregation of assets and liabilities. They’re useful when:
- A seeder wants a dedicated sleeve (e.g., lower fees, tighter risk limits) without contaminating the flagship terms.
- You plan multiple strategies or capacity‑constrained products over time.
Watchouts: Administrator and audit costs rise with each cell. Governance must keep up—each cell requires specific policies and financial reporting.
Offshore vehicles for the seeding economics
Seeders often take economics through:
- GP stake: Equity in the GP that receives incentive allocation (carry/performance fees) from the master.
- Revenue share: A percentage of management fee and/or performance fee from the manager.
- Founders class: Reduced fees for the seeder’s capital, sometimes with capacity rights.
Where offshore fits:
- If non‑U.S. seeders want economics but wish to avoid U.S. tax filings tied to advisory fee income, directing economics through the fund/GP side (rather than the U.S. advisory entity) can be cleaner, subject to careful tax design.
- Dedicated offshore SPVs can hold the seed stake, especially if multiple non‑U.S. co‑investors aggregate into one seed vehicle.
There’s no one‑size answer; test both the manager’s and seeder’s tax profiles before picking GP equity vs revenue share.
Choosing the Right Offshore Domicile
You’re balancing speed, cost, investor familiarity, and regulatory comfort.
- Cayman Islands: The default for hedge funds. Straightforward Mutual Funds Act regime for open‑ended funds. Registration is typically 4–8 weeks once documents are ready. Requires a CIMA‑approved auditor, offering document, and AML officers (MLRO, DMLRO, AMLCO). Most global primes and admins are set up for Cayman.
- British Virgin Islands (BVI): Attractive for cost‑sensitive launches. The “Professional Fund” and “Approved Fund” regimes are quick to set up. Administration ecosystem is solid, though some larger institutions still prefer Cayman branding.
- Bermuda: Strong governance reputation; slightly higher costs. Good for managers seeking a blue‑chip offshore jurisdiction with deep insurance/finance infrastructure.
- Jersey/Guernsey: Excellent for European and UK‑centric distribution. Expert/Professional Fund regimes are pragmatic. More regulator interaction and substance expectations than pure Caribbean offshore, with corresponding credibility.
- Mauritius: Sometimes used for emerging markets and Africa strategies for treaty access, but treaty shopping concerns and evolving substance rules mean more tax analysis and operational lift.
- Singapore VCC: Technically onshore, but gives similar operational benefits with strong regulator credibility. Popular for APAC managers; less common as the sole domicile for U.S.‑centric seeding.
For most hedge fund seed deals, Cayman wins on familiarity, service provider depth, and regulatory predictability.
The Tax Mechanics You Must Get Right
I’ve seen more seed deals slowed by tax missteps than by any term negotiation. Get these foundations in place before you paper economics.
Investor categories and the offshore blocker
- U.S. taxable investors: Invest via a U.S. pass‑through feeder (Delaware LP/LLC). They avoid PFIC issues and get flow‑through tax treatment.
- U.S. tax‑exempt investors: Usually prefer the Cayman corporate feeder to block UBTI, especially if the strategy uses leverage or invests through partnerships that can pass ECI/UBTI.
- Non‑U.S. investors: Generally prefer the Cayman feeder to stay out of U.S. tax filing. The U.S. trading safe harbor may protect them if investing directly via a U.S. partnership, but seeders rarely want that risk or complexity.
ECI and UBTI risks
- Trading safe harbor: Non‑U.S. investors are typically safe from ECI if the fund only trades stocks/securities/commodities and doesn’t originate loans or run a U.S. business.
- Landmines: Lending/origination, U.S. real estate, MLPs, direct investments in partnerships conducting a U.S. business, and significant short‑term lending can create ECI. Debt‑financed income can create UBTI for tax‑exempts.
- The blocker: A Cayman corporate feeder functions as a blocker. The cost is withholding on U.S. dividends (often 30% gross withholding without treaty access). Many hedge funds keep dividend exposure low or obtain manufactured dividend relief via prime broker arrangements where appropriate.
PFIC and CFC considerations
- PFIC: U.S. taxable investors invested directly in a Cayman corporate feeder generally face PFIC reporting and punitive tax unless they can make QEF/mark‑to‑market elections (often impractical). That’s why they go into the U.S. feeder.
- CFC: If more than 50% of vote/value of an offshore corporate feeder is owned by U.S. shareholders (each >10%), it can become a CFC with Subpart F/GILTI consequences. Typical master‑feeder design prevents U.S. taxable investors from owning the offshore feeder to avoid CFC issues.
Seeder‑specific tax on economics
- Revenue share from the U.S. advisory entity usually creates U.S. ECI for non‑U.S. seeders, triggering U.S. filings. Some seeders accept this; others prefer economics linked to the GP’s incentive allocation, which often takes on the fund’s character (e.g., capital gains under trading safe harbor), reducing filing friction.
- Transfer pricing and fee routing: Don’t try to push U.S. advisory income offshore without real substance and pricing support. Regulators challenge that quickly.
- Sovereign immunity: Some sovereign seeders may benefit from Section 892 treatment but still need to avoid commercial activity ECI. Keep the economics at the fund/GP level, not the advisory entity.
A 60–90‑minute tax architecture session with both sides’ advisors saves months of cleanup later.
Seeding Deal Economics: What’s Market, and How Offshore Fits
No two seed deals are identical, but the following ranges are “in the zip code” for emerging managers with solid pedigrees.
- Seed ticket size: $25–$100 million. Top‑tier accelerators can go higher. Anchors often want to be 15–35% of day‑one AUM but generally under 50%.
- Term length: 3–5 years for economics, with step‑downs or sunsets tied to AUM or time.
- Economics:
- Revenue share: 10–20% of management fees and 10–30% of performance fees from the flagship products under management, sometimes tiered by AUM.
- GP stake: 10–25% of GP economics, with buyback rights and performance/AUM‑based vesting.
- Founders class: Fee discount (e.g., 1%/10% vs 2%/20%) for the seeder’s capital, often with a 2–3 year hard lock and/or step‑up to standard fees after the seed term.
- Capacity rights: The right to maintain a fixed percentage of the fund or a fixed dollar allocation at standard fees post‑seed.
Where offshore helps:
- GP economics frequently live at the master fund level (incentive allocation to a Delaware GP). Tying seeder economics to that pool can mitigate ECI for non‑U.S. seeders and simplifies cross‑border tax.
- An offshore SPV can warehouse co‑investors in the seed economics, reducing bespoke side letters across dozens of investors.
- Dedicated offshore share classes allow customized liquidity and fees for seeders without contaminating other classes.
Governance protections for seeders:
- Key‑person triggers and early termination rights if principals depart.
- Most Favored Nation (MFN) on economic terms within the seed sleeve.
- Information rights: monthly risk/positioning summaries and quarterly deep‑dives under NDA.
- Negative consent rights on strategy drift beyond a defined mandate.
Governance and Operations That Pass Due Diligence
Seeders are exacting. They’ve seen dozens of launch files and know the red flags. Build the fund they want to invest in.
- Board/GP oversight: For corporate offshore feeders, appoint at least two independent directors with fund governance experience. For partnership feeders/masters, ensure the GP has robust policies and documented oversight.
- Administrator: Choose a top‑tier admin with strong NAV controls (SOC 1 Type 2 report), shadow NAV capability, and FATCA/CRS compliance. Expect base fees of $4–8 bps with minimums ($75k–$150k per entity, per year).
- Auditor: Big Four or top‑tier mid‑market firm with a Cayman/BVI presence. Budget $50k–$150k depending on complexity. Cayman funds must use a CIMA‑approved local auditor sign‑off.
- Prime broker/custodian: Diversify counterparty risk early—at least one primary and one backup if the strategy allows. Implement collateral management and margin stress testing policies.
- Valuation: Written policy, independent price verification, and escalation for Level 3 assets. Private Funds Act valuation rules don’t apply to open‑ended hedge funds, but investors expect equivalent rigor.
- AML/KYC: Appoint AMLCO, MLRO, and DMLRO. Implement risk‑based onboarding, PEP/sanctions screening, and periodic refresh cycles. Seeders often review your AML policies line‑by‑line.
- FATCA/CRS: Register for a GIIN, appoint a principal point of contact, and file FATCA/CRS returns via Cayman’s DITC portal. Classify correctly as an Investment Entity. Maintain self‑certs and reasonableness checks.
- Regulatory filings: Cayman Mutual Funds Act registration (for open‑ended funds with minimum initial investment >$100k), annual FAR return, audited financials to CIMA. BVI/Bermuda/Jersey have parallel regimes.
- Cyber and operational resilience: Written incident response plan, vendor due diligence, privileged access controls, MFA, and regular penetration tests.
Indicative timelines: With documents prepared, you can register a Cayman fund in 4–8 weeks. From zero to launch, budget 8–12 weeks if service providers are responsive and tax structuring is straightforward.
A Step‑by‑Step Playbook for Using Offshore Funds in Seeding
Phase 0: Pre‑seed groundwork (2–3 weeks)
- Map investor base by tax profile and geography; estimate day‑one AUM mix (U.S. taxable vs tax‑exempt vs non‑U.S.).
- Align seed economics priorities: capacity, fee discounts, GP vs revenue share.
- Hold a joint tax workshop with both sides’ counsel to decide on master‑feeder vs stand‑alone, GP economics locus, and any SPVs.
Deliverable: One‑page structure memo with diagrams and tax notes.
Phase 1: Term sheet and structure design (1–2 weeks)
- Negotiate headline terms: capital size, lock, liquidity, founders fees, economics split, key‑person, sunset, capacity rights, information rights, and termination triggers.
- Decide domicile and entity forms (e.g., Cayman exempted company feeder + Cayman LP master + Delaware LP feeder).
- Confirm auditor, admin, and directors availability and fees.
Deliverable: Executed non‑binding term sheet with a timeline.
Phase 2: Formation and documentation (4–8 weeks)
- Constitutive docs: Memorandum and Articles, partnership agreements, subscription docs.
- Offering docs: PPM with classes and seed sleeve disclosures.
- Seed agreements: Seed investment agreement, GP/manager side letter(s), revenue share or option agreements.
- Policies: Valuation, liquidity management (gates, suspensions), side pocket policy if applicable, AML manual, cyber policy.
- Regulatory: CIMA registration, FATCA/CRS registrations, GIIN, AML officer appointments.
Deliverable: Complete launch pack, draft seed agreements, and regulator submissions in progress.
Phase 3: Funding and launch (1–2 weeks)
- Finalize KYC on the seeder and early LPs. Test subscription and capital call mechanics.
- Dry run NAV and trade booking with admin. Confirm banking, FX, and collateral lines.
- Close the seed and open for additional subscriptions under founders class.
Deliverable: Day‑one AUM funded; trading live; NAV timetable in place.
Phase 4: Post‑close assurance (first 90 days)
- First monthly NAV and investor reporting. Validate fee calculations, class accounting, and equalization mechanics.
- Seeders’ information rights kick in; hold a 60‑day operating review covering risk, drawdowns, and pipeline.
- File initial FATCA/CRS and regulator confirmations; onboard any follow‑on side letters under MFN guardrails.
Deliverable: Post‑launch ops memo and KPI dashboard to the seeder.
Documentation Map
Expect this set:
- Fund constitutional documents (Cayman: M&A for companies, LPA for partnerships).
- Offering memorandum with risk factors, fee table, valuation and liquidity sections, and class‑specific disclosures.
- Subscription booklet with FATCA/CRS self‑certifications and AML requirements.
- Investment Management Agreement between the fund and the adviser.
- GP/Carry LPA and related management company agreements.
- Seed investment agreement:
- Economics schedule (revenue share or GP stake).
- Liquidity and lock‑up terms.
- Capacity rights.
- Key‑person and termination provisions.
- Information and audit rights.
- Buyback/call/put mechanics at pre‑agreed valuation formulas.
- Side letters and MFN protocol.
- Service provider agreements: administration, prime broker, ISDAs/CSAs, audit, directors.
Common friction points:
- MFN scope: Define what’s in and out (e.g., regulatory accommodations vs cash economics).
- Cross‑defaults: Ensure seed agreement remedies don’t inadvertently trigger fund‑level suspensions.
- Transfer rights: Clarify if the seeder can transfer economics to affiliates or sell into a secondary.
Costs, Timelines, and Resourcing
Ballpark budgets I’ve seen hold up across launches:
- Legal (fund + seed docs): $200k–$400k for straightforward deals; $500k+ for multi‑sleeve/SPC or complex tax overlays.
- Administrator setup: $25k–$75k one‑off; annual minimums $75k–$150k per entity.
- Audit: $50k–$150k per year depending on complexity and number of entities.
- Directors: $10k–$25k per director per year; two independents is typical.
- Miscellaneous: Regulatory fees, KYC providers, cyber tooling ($25k–$75k), compliance consulting ($50k–$150k).
From term sheet to trading, 8–12 weeks is achievable. Add time for multi‑jurisdictional SPVs, EU marketing, or bespoke custodial set‑ups.
Worked Examples
Example 1: U.S. long/short equity with a non‑U.S. anchor
Context: Manager with $10m friends‑and‑family asks a Middle Eastern family office to anchor with $50m. Expected investor mix is 60% non‑U.S., 40% U.S. taxable by year two.
Structure:
- Cayman master‑feeder with Delaware LP feeder for U.S. taxable.
- Cayman corporate feeder for non‑U.S. and U.S. tax‑exempt.
- Seed economics via a 15% share of GP incentive allocation for 4 years, stepping down to 7.5% for years 5–6, plus founders share class at 1%/10% for seed capital.
Rationale:
- Avoids PFIC/CFC issues for future U.S. taxable investors.
- Non‑U.S. seeder ties economics to fund‑level carry, mitigating U.S. ECI exposure.
- Founders class locks in a compelling all‑in fee while capacity rights guarantee the seeder can maintain $75m at standard fees post‑term.
Outcomes:
- Achieved $125m AUM within 18 months. The GP buyback right at 6x trailing 12‑month GP distributions gave a clean path to unwind the seed economics later.
Example 2: Macro fund with ERISA and endowment interest
Context: Strategy uses leverage and swaps, attracting U.S. tax‑exempts and some ERISA plans. Seeder is a U.S. fund‑of‑funds committing $35m with a 3‑year hard lock.
Structure:
- Cayman master‑feeder with Cayman feeder as blocker for tax‑exempts and non‑U.S. investors.
- U.S. feeder for U.S. taxable and ERISA. Plan assets analysis confirms less than 25% plan investor threshold at each entity to avoid ERISA plan assets rules.
- Seeder economics via 20% revenue share on management fees from flagship products for 3 years, with an option to convert to a GP stake at a pre‑agreed multiple.
Rationale:
- Blocker protects tax‑exempts from UBTI due to leverage.
- ERISA 25% test monitored per class to keep the fund out of plan assets status.
- Revenue share suits the U.S. seeder, who accepts U.S. filings; conversion option gives upside if performance fees ramp.
Outcomes:
- Reached institutional diligence gates quickly. The plan assets guardrails and independent valuation oversight satisfied ERISA counsel and unlocked additional allocations.
Common Mistakes and How to Avoid Them
- Using the wrong vehicle for the investor mix. If U.S. taxable money is anywhere in sight, build the master‑feeder from the start. Conversions later are doable but cost time and investor patience.
- Ignoring PFIC and CFC pitfalls. Letting U.S. taxable investors into an offshore corporate feeder creates PFIC headaches. Avoid it with a U.S. feeder.
- Poorly drafted founders classes. Overly generous liquidity for the seed class can destabilize the fund during drawdowns. Use a hard lock or meaningful early‑redemption fees.
- MFN traps. Offering too many bespoke economics invites MFN contagion. Segment commercial terms from regulatory/admin accommodations and cap MFN to investors above a size threshold.
- Weak AML and FATCA/CRS processes. Seeders often ask for your AML manual and testing plan. Appoint qualified AML officers and keep evidence of training and file submissions.
- Over‑concentrated governance. One friend as director isn’t enough. Use independent directors with demonstrated oversight records.
- Sloppy valuation around Level 3 assets. Even if you hold a few private warrants, you need a formal policy, model governance, and independent review.
- Underestimating ECI on revenue shares. Non‑U.S. seeders offered a cut of U.S. advisory fees often balk at U.S. filings. Shift economics to the GP/carry when that aligns with both parties’ tax comfort.
- No clear buyback path. Seed economics without priced buyback options or sunsets become relationship‑damaging later. Bake in step‑downs, caps, and formulas at the outset.
- Neglecting ERISA. If you admit benefit plan investors, monitor the 25% plan assets test per class and per entity. Missteps limit investment flexibility.
Practical FAQs
- Do I need independent directors for a Cayman LP master? Strictly, no board, but investors want governance. Appoint an advisory board for the GP, and use independent directors on the corporate feeder.
- Can I run without an administrator at launch? Technically possible for some jurisdictions, but a non‑administered hedge fund is a red flag for serious seeders. Use a recognized admin from day one.
- How fast can I launch? With documents ready and responsive providers, 8–10 weeks is achievable for a standard Cayman master‑feeder.
- What’s the right gate and lock combination? Common patterns: 1–2 year hard lock for founders class; thereafter quarterly liquidity with 25% gate at the class level and 30–90 days’ notice.
- Do I need economic substance in Cayman? Investment funds are generally out of scope of Cayman’s economic substance regime, but Cayman‑based managers may be in scope. Keep your manager/adviser location and functions consistent with your filings.
- Can the seed be warehoused in an SPC cell? Yes. An SPC can segregate the seed sleeve (lower fees, bespoke liquidity) while preserving flagship terms for others. Weigh added complexity and cost.
- Will withholding on U.S. dividends hurt offshore investors? It’s a cost, but most hedge funds limit net dividend exposure through strategy design or utilize broker programs where allowed. Model the drag; often it’s 10–40 bps annually for typical long/short books, but it varies.
Managing Liquidity, Risk, and Reporting
Liquidity terms interlock with seed economics. If a seeder negotiates a founders share class:
- Use hard locks for 1–3 years for stability; backstop with gates rather than suspension.
- Consider early‑withdrawal fees that accrete to the fund to protect staying investors.
- Equalization: Make sure your admin can handle equalization credits for performance fees across classes and dealing dates.
Risk reporting that impresses seeders:
- Monthly exposures by asset class, net and gross, factor decompositions for equity strategies, VaR bands for macro, and stress scenarios tied to historical events.
- Drawdown governance: pre‑defined risk “rails” that trigger de‑risking conversations with the GP and board.
- Transparency boundaries: offer depth without disclosing proprietary trade secrets; use lags for position‑level reports if needed.
Marketing and Regulatory Considerations
Offshore funds don’t absolve you from marketing rules.
- U.S. advisers: If under the private fund adviser exemption (ERA), you still owe Form ADV‑Part 1 and state-level requirements. Track Form PF thresholds as you scale (e.g., $150m RAUM for smaller filers; more rigorous reporting as you grow).
- EU/UK: AIFMD restrictions apply if you’re marketing into the EU/UK. National Private Placement Regimes (NPPR) may suffice for a handful of countries. For heavy EU distribution, consider an EU AIF (e.g., Irish QIAIF) or a third‑party AIFM platform.
- Asia: Jurisdiction‑specific rules (e.g., SFC in Hong Kong, MAS in Singapore). Many managers use reverse‑enquiry frameworks and local placement agents.
Maintain a marketing log, pre‑approve materials, and tailor PPM disclosures to actual practices—seeders compare marketing decks to offering docs line‑by‑line.
Exit Planning for the Seed
No one wants to argue about value once the fund is successful. Hard‑wire the exit mechanics.
- Sunset: Seed economics step down and/or end after a defined term or AUM threshold.
- Buyback: The manager can buy back GP/revenue share at a formula (e.g., a multiple of trailing 12‑ or 24‑month distributions, with performance adjustments).
- Drag/tag: If the manager sells a stake in the GP, the seeder has tag‑along rights; if the manager consolidates economics, a drag may apply with fair value.
- For cause termination: Misconduct, breach of investment mandate, regulatory events, or sustained drawdowns beyond agreed thresholds can shorten the seed term.
- Secondary: Permit the seeder to transfer economics to affiliates or via a controlled secondary sale, subject to manager consent (not to be unreasonably withheld) and KYC.
Disputes are rare when parties invest time upfront in clear, testable definitions: “net revenues,” “flagship products,” “AUM” (net or gross?), and “distributions” should be unambiguous.
Personal Notes from the Trenches
- Start with the tax whiteboard. The cleanest term sheet in the world won’t survive a late revelation that your non‑U.S. seeder is picking up U.S. ECI or that your U.S. taxable pipeline can’t touch the offshore feeder.
- Pay for real governance early. Two seasoned independent directors and a respected admin cost money but pay for themselves the first time you hit a rough patch or need a gate.
- Don’t over‑optimize fee splits on day one. The delta between a 15% and 17.5% revenue share matters less than reaching $250m AUM with stable investors and low operational friction.
- Be explicit about strategy scope. Seeders don’t hate innovation; they hate surprises. If you plan to add a credit sleeve or private investments, build optionality into the documents now.
- Build MFN hygiene. Track every side letter in a matrix and prepare MFN packets in advance. Administering MFN post‑close can swallow weeks if you’re not ready.
Quick Checklist: Using Offshore Funds in a Seed
- Investor map built and structure selected (master‑feeder vs stand‑alone).
- Domicile confirmed; service providers engaged with fee quotes.
- Tax analysis completed for U.S. taxable, U.S. tax‑exempt, non‑U.S., and the seeder’s economics.
- Seed term sheet signed with clear definitions, key‑person, and exit mechanics.
- Offering docs drafted with founders class, liquidity, and valuation policies.
- Cayman registrations: Mutual Funds Act, CIMA auditor appointed, AML officers named, FATCA/CRS set.
- Admin NAV model tested; equalization and class accounting verified.
- Side letter and MFN framework locked.
- Reporting pack agreed with the seeder (monthly/quarterly cadence).
- Buyback/sunset mechanisms clear, with step‑downs tied to time and AUM.
A well‑designed offshore structure won’t win the seed on its own—but a sloppy one can lose it. Treat the offshore fund as the platform for trust: align it with your investor mix, make the economics transparent, and install governance that you’d be happy to defend in a room full of institutional CIOs. When those pieces are in place, the rest of the conversation shifts to where it should be: your edge, your risk discipline, and your path to compounding capital over decades.
Leave a Reply