We advise family offices and other investment companies with internationally based investors on the UK, US and international tax implications of investment into various investment structures. This includes guidance on the UK and US tax ramifications of investing in private funds through international structures, including companies and partnerships.
We also advise on anti-avoidance rules applicable to structures with UK connections, including the law on the taxation of capital gains and the various provisions for the taxation of UK beneficiaries and settlors where structures include offshore settlements.
We are well versed in the liquidity constraints on funds whose underlying investments may have substantial holding periods, and the need for lockups and gates on investors and vesting and claw backs on employees.
Our clients include family offices and large international investment managers with significant portfolios to invest.
- Advising on proposed investments in funds based in various countries worldwide, by Cayman Island investment companies within a trust structure with UK beneficiaries.