Tax issues are a key factor in the success of international investment vehicles such as hedge funds, private equity funds and other types of funds.
Our tax team advises clients on all the tax aspects of structuring such funds. Often, this involves advising on corporate residence and trading issues, which impact on tax considerations, as well as the application of the Investment Manager Exemption in the UK.
In the US, we work on tax issues relevant to both managers and investors. These may involve, for example, the deferral of fee income and retention of the character of tax-favored types of income. We are particularly knowledgeable in the reduction of the UK inheritance tax and US estate tax burdens on interests in fund management companies.
Clients often request guidance on the vehicle through which funds should be invested and the regulatory issues arising as a consequence. In this context, we have considerable experience in the use of Dutch and Luxembourg mixer companies, and the use of double taxation treaties to achieve an optimal taxable position for a fund.
We act for established fund managers and start-up funds based worldwide.
- Advising on the structure of a private equity fund with a value of $500m, to be set up in the Isle of Man with a mandate to invest into CIS countries.
- Providing advice on opening a UK office for a US-based hedge fund manager with $2 billion under management.