Congress said borrowers in taxpayer-backed rescue programs had to be from the United States. Wall Street has a workaround. : Congress said borrowers in taxpayer-backed rescue programs had to be from the United States. Wall Street has a workaround. WASHINGTON — Pacific Investment Management Company runs a hedge fund registered in the Cayman Islands, a common structure for avoiding certain U.S. taxes. But when a profit opportunity arose from the ashes of America’s coronavirus crisis, that international location did not stop it from seizing the moment.