Background:
ATF is a company largely owned by Australian public sector research
organisations, mainly universities and equivalent.  ATF is
establishing a fund to invest in opportunities emerging from its
members (shareholders).  Opportunities include research capabilities
and new technologies.
A powerful and wholly unique feature of the fund will be the ability
to 'place' opportunities throughout Asia through the resources of the
FBR Group, Asia's leader in international business development.  This
ability serves to link the research providers (Australian
universities, etc) and research users (Asian businesses).
The fund will invest (or more accurately 'co-invest' with the
respective 'research user' in each case) across a wide range of
stages; this spans collaborative early-stage research, through
start-ups and licensing, to emerging multi-national corporations.

The 'fund':
The objective of the fund will be to maximise medium term capital
growth.
The target size for the fund is US$150million, probably in 3 tranches
of US$50m, with investors in the first tranch having the opportunity
to secure their position in the 2nd and 3rd tranches.
Investors are expected to be from the institutional/government sector,
each investing at least US$8m, and to be predominantly based in Hong
Kong, Singapore, Taiwan, Oman, United Arab Emirates and Brunei.
The fund may seek a listing on  Hong Kong or  Singapore exchanges in
3-4 years.

The Question:
(a) In order to maximise the fund's appeal to its target investors
from a tax perspective, what should be the legal form of the fund? 
(Company, Fund, Trust, ...) and where should the fund be legally
based?
(b) How should the tranches be structured?  (As three separate
raisings, or multiple draw-downs on a single commitment, or some other
way?)