Jon Hanifan

Jon Hanifan

Akin Gump Strauss Hauer & Feld LLP

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Latest Publications


UK tax treatment of US LLCs: HMRC responds to the Supreme Court’s decision in Anson v HMRC

Executive Summary - Her Majesty’s Revenue & Customs (HMRC) has now published its response to the U.K. Supreme Court’s recent judgment in Anson v HMRC. The response confirms that HMRC will continue its existing practice...more

9/28/2015 - Double Taxation HMRC Income Taxes Limited Liability Companies UK Supreme Court

UK Summer Budget 2015

On Wednesday, 8 July 2015, George Osborne delivered the UK Summer Budget. The first Budget of the new Conservative government (and the second Budget of 2015), the Summer Budget is wide-ranging in scope and potentially...more

7/13/2015 - Asset Management Banking Sector Capital Gains Corporate Taxes Derivatives Federal Budget Goodwill Peer-to-Peer Pensions Stamp Duty Land Tax Tax Credits Tax Reform Tax Revenues UK

UK Budget 2015: Key Implications for Alternative Asset Managers

In a speech crammed full of digs aimed at opposition parties (and the French), the UK’s Chancellor of the Exchequer delivered his final pre-election Budget this afternoon....more

3/19/2015 - Asset Management Corporate Taxes Investment Management UK

Draft Finance Bill 2015: Key Implications for U.K.-Based Alternative Asset Managers and Their Funds

Following not quite so hotly on the heels of the Autumn Statement as some would like, the U.K. government has now published draft legislation for inclusion in next year’s Finance Bill. ...more

12/12/2014 - Alternative Investment Funds Asset Management Derivatives Fees UK

FATCA — Final Deadline to Obtain a GIIN for Model 1 IGA FFIs

Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account...more

12/8/2014 - Deadlines FATCA FFI GIIN IRS

Autumn Statement 2014: Key Implications for U.K.-Based Alternative Asset Managers and Their Funds

Shortly after 12.30 p.m. today, the U.K. Chancellor of the Exchequer, George Osborne, delivered the last Autumn Statement before next year’s general election....more

12/4/2014 - Corporate Taxes Tax Reform UK

UK Implementation of AIFMD – Transitional Period Extended

In December 2013, HM Treasury announced that the transitional period allowing existing U.K. alternative investment fund managers (AIFMs) to continue managing their alternative investment funds (AIFs) without receiving...more

6/30/2014 - AIFM Financial Conduct Authority (FCA) Treasury UK

Finance Bill 2014 Published

The U.K. government has today published the final text of the 2014 Finance Bill. As discussed in our previous Alert, issued on March 19, the Finance Bill includes...more

3/28/2014 - AIFM AIFMD HMRC Income Taxes Stamp Taxes Tax Reform UK

2014 U.K. Budget: Impact on Alternative Asset Managers

Chancellor George Osborne delivered his fifth coalition Budget today. In a wide-ranging statement, there are a significant number of tax-focused proposals that will make changes across the U.K. tax system. Some of these...more

3/20/2014 - AIFM AIFMD Business Taxes Corporate Taxes HMRC Stamp Duty Land Tax UCITS UK

Salaried Members Legislation & Alternative Investment Fund Manager (AIFM) Deferral Mechanism

Draft Salaried Member Legislation - Following the publication of further guidance on February 21, 2014, Her Majesty’s Revenue & Customs (HMRC) in the U.K. has today issued revised “salaried member” legislation in...more

3/12/2014 - AIFM HMRC Income Taxes Tax Deferral

U.K. Partnership Tax Changes

Slightly later than first advertised, Her Majesty’s Revenue & Customs (HMRC) has now issued further guidance regarding the employment status of members of U.K. limited liability partnerships (LLPs)....more

2/25/2014 - Business Taxes Partnerships UK

FCA Publishes Final Guidance on AIFMD Remuneration Requirements

This alert will be of interest to FCA-authorised investment management firms that are registering, or are currently considering registering, as alternative investment fund managers (“AIFMs”). ...more

2/3/2014 - AIFM AIFMD Compliance EU Financial Conduct Authority (FCA) Remuneration UK

U.K. Autumn Statement 2013

The Chancellor of the Exchequer today delivered a 130-page Autumn Statement that contained a number of surprises, as well as expected updates on areas such as partnership taxation....more

12/6/2013 - Business Taxes Corporate Taxes Limited Partnerships Loans Partnerships Self-Employment Tax UK

U.K.-Cayman IGA Signed

The United Kingdom (U.K.) has published an agreed intergovernmental agreement (IGA) with the Cayman Islands. The IGA was signed on 5th November and is intended to improve international tax compliance by providing for domestic...more

11/7/2013 - Compliance IGAs International Tax Issues Tax Treaty UL

AIFM Remuneration Code Guidance

Summary - The UK’s Financial Conduct Authority (“FCA”) has published draft guidance on the application of rules on remuneration (the “AIFMD Remuneration Rules”) to FCA-authorized firms, once they become authorized as...more

9/10/2013 - AIFM AIFMD Financial Conduct Authority (FCA) Remuneration UK

Fund Board Meetings in the United Kingdom

The Background - As part of the Budget 2013, U.K. Treasury announced the U.K.’s investment management strategy. The strategy is aimed at enhancing the U.K.’s position as a global leader in the investment management...more

8/29/2013 - Board of Directors Fund Managers UK

AIFMD Update: U.K. Complies with Remuneration Guidelines

The U.K. Financial Conduct Authority (FCA) has written to the European Securities and Markets Authority (ESMA) to confirm that the FCA will comply with the ESMA guidelines relating to remuneration policies under the...more

8/9/2013 - AIFM AIFMD EEA ESMA Financial Conduct Authority (FCA) Notice Requirements Remuneration

AIFMD Transitional Relief in Germany, Ireland, Luxembourg, Netherlands, Sweden and the United Kingdom

The Alternative Investment Fund Managers Directive (AIFMD) is due to take effect in member states of the European Economic Area (EEA) on July 22, 2013. Some EEA member states (including Germany, Ireland, Luxembourg,...more

7/11/2013 - AIFM AIFMD EEA EU Foreign Investment Foreign Markets Investment Funds Investors Private Placements UK

AIFMD Update – German Private Placement Rules

Our Investment Funds group has received an update on the changes to the private placement rules for marketing of alternative investment funds (“AIFs”) in Germany following the implementation of the Alternative Investment Fund...more

7/5/2013 - AIFM AIFMD Banks Compliance EU Foreign Banks Foreign Investment Investment Funds Private Equity Private Equity Funds Private Placements

U.K.’s Financial Conduct Authority Publishes Final Rules On AIFMD Implementation

The U.K.’s Financial Conduct Authority (FCA) has published today, a policy statement that sets out its responses to the various consultations that have been undertaken in respect of the rules to be adopted by the FCA to...more

7/1/2013 - AIFMD Alternative Investment Funds ESMA EU False Claims Act (FCA) Safe Harbors

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