Demonstration mode. Northwater and Meridian are illustrative files, not clients.
Jurisdictions
A comparison of names, vehicles, and the authority counsel will mention. It does not rank them, and it does not say which one is yours. Filters and models can wait. The distinctions below are the ones that change the conversation.
Read with the formation guide.
| Place | Vehicle often discussed | Authority counsel names | How it tends to come up |
|---|---|---|---|
| Delaware | Limited partnership, usually with an LLC general partner | Delaware Division of Corporations. US securities law is a separate question for counsel. | Often discussed when US taxable investors are expected to subscribe directly. |
| Cayman Islands | Exempted company or exempted limited partnership | Cayman Islands Monetary Authority. The Private Funds Act and the Mutual Funds Act are different regimes. | Often discussed for a master fund or an offshore feeder. |
| British Virgin Islands | Business company or limited partnership | The Financial Services Commission. The Securities and Investment Business Act is the statute counsel opens. | Often discussed as an offshore fund or feeder. |
| Luxembourg | SCSp, or a RAIF where an authorised manager is already in place | Commission de Surveillance du Secteur Financier (CSSF). | Often discussed for European institutional capital, once the manager's own status is known. |
| Ireland | ICAV or investment limited partnership | Central Bank of Ireland. QIAIF is a category counsel will recognise. | Often discussed alongside Luxembourg when European distribution is on the table. |
| Malta | Vehicles counsel may describe as a professional investor fund or a notified PIF | Malta Financial Services Authority. | Sometimes discussed as an EU alternative. Whether it fits is counsel's work. |
| Jersey and Guernsey | Expert funds, private funds, and partnership forms, as counsel classifies them | Jersey Financial Services Commission, or the Guernsey Financial Services Commission. | Often discussed for non-US investors who already use the Channel Islands. |
| Singapore VCC | Variable capital company | Monetary Authority of Singapore. | Often discussed when the manager's business is already in Singapore. |
The Delaware Revised Uniform Limited Partnership Act is the statute counsel will open. Delaware does not approve a hedge fund. We do not form the entity.
Counsel determines which regime, if either, applies, and who files. We track the checklist.
Approved funds, private funds, and other categories are counsel's classification, not ours.
Whether a product needs CSSF approval is a legal conclusion. A RAIF is not a recommendation.
The Central Bank's process belongs to counsel and the manager. We do not authorise a fund.
We record the questions. We do not choose Malta over another domicile.
The two islands are not interchangeable. Counsel says which commission, if either, is relevant.
A VCC is a corporate form, not a statement that the fund may be offered. Offering rules are counsel's.
This page is not legal, tax, or investment advice, and it is not a recommendation of any domicile. Regulatory names are orientation for counsel. An inquiry does not create a client relationship. Figures and structures elsewhere on the site are illustrative.