Onshore Alternatives for Offshore Structures?
Been giving some thought lately to the increasing scrutiny on traditional offshore jurisdictions. Not just the tax aspect, but the operational headaches for clients – compliance costs escalating, banks becoming incredibly risk-averse. It's making me wonder if the push for 'substance' is fundamentally changing the game. Are we seeing a legitimate shift, where the benefits of certain offshore structures are being eroded to the point that well-designed onshore alternatives, perhaps in more favourable domestic tax regimes, are actually becoming more efficient?
For instance, for simple holding company structures or even certain investment vehicles, is the juice still worth the squeeze when you compare the hassle factor with, say, a well-structured Delaware LLC or even some European domestic options with appropriate tax treaties? I'm not talking about anything illicit, purely compliant strategies. The cost-benefit seems to be tilting. What are your thoughts? Am I off base here, or are others seeing a similar trend?
The 'substance' requirement is definitely a game-changer, but it's more about re-routing than eliminating the benefits. Finding onshore alternatives with similar tax efficiency without losing operational flexibility is the real challenge, and frankly, a lot of firms are still struggling to adapt.