Daniel Hawthorne

Daniel Hawthorne

Dechert LLP

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UK Taxation Update for Investment Managers

The shifting sands of the taxation landscape for investment managers continues apace. Just when you perceive an oasis of stability on the horizon, it is revealed to be a mirage by the announcement of yet further changes....more

4/1/2016 - Anti-Avoidance Carried Interest Carried Interest Tax Rates HMRC Income Taxes Investment Management Management Fees UK

Financial Services Quarterly Report - Fourth Quarter 2015: Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

12/30/2015 - Capital Gains Carried Interest Carried Interest Tax Rates Financial Services Industry HMRC Investment Funds UK

Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

12/11/2015 - Capital Gains Carried Interest Carried Interest Tax Rates HMRC Non-Domiciled Investors UK

UK tax treatment of US LLC: HMRC’s practice following Anson

We reported earlier this year on the UK Supreme Court’s decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to claim relief against his UK tax liabilities for US tax paid on his share of...more

10/1/2015 - Anson v HMRC Business Taxes Double Taxation HMRC Limited Liability Company (LLC) UK UK Supreme Court

HMRC Consults on Tax Residence of Non-UCITS Funds Managed by UK Managers

HMRC has released a series of consultations regarding financial services taxation. The proposed measures are in line with the Government’s “UK investment management strategy”, a commitment announced in the 2013 Budget to...more

7/25/2013 - AIFM Asset Management Fund Managers HMRC Tax-Residency Certificate UCITS UK

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: Privilege and Prudence

Legal advice privilege has seized the focus of attention yet again, as a result of the UK Supreme Court’s decision in Prudential delivered on 23 January 2013. In overview, Prudential sought to withhold documents including...more

2/14/2013 - Accountants EU HMRC Legal Advice Privilege Prudential

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: FATCA Update – No Duplicate Reporting for Investment...

Following the execution of an inter-governmental agreement (or “IGA”) with the United States in September 2012 and a consultation exercise which closed in late 2012, HM Revenue & Customs (“HMRC”) recently published draft...more

2/8/2013 - EU FATCA HMRC Intergovernmental Agreements Investment Funds Investment Management IRS Partnerships

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