In a side-by-side structure, U.S. investors typically invest in a limited partnership organized in the United States, and offshore investors invest in an offshore corporation. The prime broker typically allocates trade tickets between the domestic fund and the offshore fund.

For hedge fund managers seeking to establish both a domestic and an offshore fund, there are various tax, administrative and other issues the manager should consider in determining whether to utilize a master-feeder or a side-by-side structure. The choice will depend on the manager’s strategy and goals.