b'yourU.S.company.Thisapproachmayprovidetaxsavingstoyour investors in their home country. There is no one size fits all approach as to which offshore jurisdiction is best.The best structure for your investors will ultimately depend on: The tax treaty between the U.S. and the investors home country,The tax treaty between the U.S. and the offshore jurisdiction, andThat jurisdictions tax treaty with the investors home country.If you plan to create an offshore blocker entity, you should anticipate that the costs of your syndication, as well as annual administration costs, will be substantially more than simply forming a U.S. entity and bringing foreign investors into your U.S. syndication.Foreign Tax Laws Non-U.S. persons may also be taxed in their own country on earnings fromtheirU.S.investments.Anissuershouldavoidgivingnon-U.S. persons any tax or legal advice, but the issuer does have an obligation to warn non-U.S. persons that potential tax consequences may exist, which coulddramaticallyaffecttheirreturns.Aprospectivenon-U.S.investor should consult their own legal/tax advisers to determine the U.S. and non-U.S. tax consequences of investing in a U.S. securities offering; or you should do some advance tax planning to set up offshore blockers that will give them specific tax advantages.78'