Please can you assist me? I am located in Mauritius and am establishing a novel investment fund (which will be licenced by the FSC,in Mauritius and we will do all KYC, and due diligence, source of funds, and anti-money laundering checks on all potential investors). The fund is novel, as we have subscribed to various Investment Newsletters in the US
, and have developed proprietary in-house software
to 'amalgamate' the Newsletters 'picks' of listed securities into our portfolio, classified by conservative, medium or high risk, and also sector, retail, REITS, pharmaceuticals etc. Not more than 3% of the model portfolios will be invested in any one security. The model portfolio we have constructed is a balance of income
and capital growth stocks. We understand that there is no Capital Gains tax
payable by a Mauritian fund investing in the US through a US Broker (Interactive Brokers) London office is our proposed broker...but my question is simple...to mitigate or reduce the 30% withholding
tax on dividends
upon payments to the Mauritius fund by the listed US corporations what "Treaty Shopping" can be done to identify the most tax advantageous jurisdiction to reduce the withholding tax on dividends paid. When you have identified suitable jurisdictions we will use the Mauritius fund as a 'feeder fund' and incorporate and register and have the fund regulated in the most tax favourable jurisdiction. Also what procedure do we have to undertake to obtain consent to allow marketing of the fund to US Citizens/Residents/Green Card Holders? I look forward to the pleasure of hearing from you in reply, and in the meantime remain, with my best regards.