Here are two things that every offshore fund manager should take away from any discussion of United States federal income tax:

  • It is easy to be deemed engaged in a U.S. trade or business; and,
  • It is bad to be deemed engaged in a U.S. trade or business.

The Alert “Four Things That Offshore Funds Should Not Do”, authored by John Kaufmann, Greenberg Traurig of counsel in the New York office, describes four situations in which offshore funds may unwittingly become engaged in a United States trade or business. To learn more about these four situations, please click here.