This paper explains the various structures that permit offshore funds with U.S. managers to originate loans without the fund or its investors being subject any meaningful amount of U.S. tax. This paper also suggests a legislative change that would render these structures moot

The Internal Revenue Code is riddled with features that allow U.S. taxpayers to reduce their federal tax liability by operating through tax haven companies. Some of these provisions are historic anomalies. Others are better understood as inadvertent loopholes than considered legislative grace....