| | Curtis, Mallet-Prevost, Colt & Mosle LLP - investment management attorneys - common law |
 | | This article will expand upon the prior article and discuss (a) the benefits of using limited partnerships organized outside the United States for this purpose, and (b) certain U.S. tax treaty benefits that could be obtained by investing through limited partnerships as opposed to other investment entities, such as offshore companies. |
 | | Partnerships Organized Outside the U.S. While U.S. investment partnerships are organized in various states under their versions of the Uniform Limited Partnership Act, there are other jurisdictions in which organizations can be created which will be treated as limited partnerships for U.S. tax purposes. |
 | | If the partnership is organized in the United States, it will have to file a U.S. Federal income tax return annually for the purpose of reporting each partner's allocable portion of income and gains, whether or not the partnership is engaged in trade or business in the United States ("ETB"). |
| www.cm-p.com /publications_newsletters_1995_may_offshore.htm (1041 words) |