Descriptive Notes And Contents List

The first section of the report studies the booming offshore funds sector. We analyse the growth of offshore funds from humble beginnings until now they challenge their onshore competitors, using the Internet to keep up with innovation in marketing and product development. For the eighteen top offshore jurisdictions we describe the funds sector and its legislative base, noting recent developments.

The second section of the report studies offshore stock markets, making the controversial claim that one day they will rival and even eclipse their grand onshore counterparts by linking with electronic newcomers to develop pools of liquidity in low-tax jurisdictions. There are thirteen offshore stock-markets and for each one we describe its history, its regulatory environment, its size and its growth pattern.

The Trusts section of the report studies the 20 top jurisdictions which offer trust regimes. It's a fairly well known fact that the trust originated in England many hundreds of years ago, and that its purpose was to preserve assets against depredations occurring through death, matrimonial and family squabbles, spendthrift descendants and the like. Taxation at death was one of the incidents that trusts were effective against, but they were not particularly designed to guard against the taxation of income or capital during the settlor's life, because such taxes were not a major threat to wealth at the time, and anyway a domestic trust was a taxable person in itself. Now the trust is a major component of asset protection structures, as well as having many business uses.

The final section of the report studies the draconian new US withholding tax rules and qualified intermediary status which applied from January 1 2001. The new regime affects every non-US based investor with US source income, and every non-US based financial institution which handles such income. We explain the legislation and give its full text, along with a copy of the contract qualified intermediaries sign with the IRS, which effectively turns them into tax collectors! We also set out the rules to be followed in each of the countries 'approved' by the IRS.

Offshore Investment Funds

Introduction: What is an Offshore Investment Fund

Characteristics of the Offshore Fund Industry

Recent Developments in the Offshore Fund Industry

Onshore Responses To The Hedge Fund Boom

The Internet's Role In The Offshore Investment Process

Offshore Investment Funds: The Jurisdictions

Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Cyprus, Gibraltar, Guernsey, Hong Kong, Ireland, Isle of Man, Jersey, Luxembourg, Malta, Mauritius, Netherland Antilles, Seychelles, Switzerland and Turks & Caicos Islands.

Offshore Stock Exchanges

Introduction: The Evolution of Offshore Stock Exchanges

Enter the Internet

Enter the OECD

The Jurisdictions with Stock Exchanges

Bahamas Bermuda Cayman Islands Costa Rica Cyprus Guernsey Hong Kong

Ireland Luxembourg Malta Mauritius Panama Switzerland

Offshore Trust Regimes

Introduction: The History of Offshore Trusts

Development of Professional Competence in the Jurisdictions

What Future for the Trust

The Jurisdictions

Bahamas Barbados Bermuda British Virgin Islands Cayman Islands Cook Islands Cyprus Gibraltar Guernsey Isle of Man

Jersey Liechtenstein Madeira Malta Mauritius Monaco Panama Seychelles Turks & Caicos Vanuatu

The US Qualified Intermediary Regime

Introduction: What The Legislation Does

Annex I: Full Text Of IRS Tax Code Section 1.1441

Annex II: 'Attachments' For 48 Approved Countries

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