Biotech Values

[mouton29]

Most hedge funds are organized in a master-feeder or parallel fund structure, with an offshore entity and domestic entity. The offshore entity is taxed as a foreign corporation and has US tax exempt ( mainly pension funds) and foreign investors and it is not subject to tax on capital gain, short or long. The US side frequently makes a mark to market election under code section 475 and so is indifferent about gain recognition.