Like so many things, it was conceived during the halcyon days of the Celtic Tiger.  A major financial institution tapped high-net-worth clients to invest in overseas property, promising high returns and a tax-efficient corporate structure. The investments were made through an offshore vehicle via capital contributions and interest-free, non-recourse loans. The plan was to buy properties, flip them at a profit as the market rose, and then distribute the profits by way of dividends after liquidating the offshore entity.  Investors were enthused.  The fund was initially expected to raise between €100 million and €150 million. By the time it closed,…

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