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Never content to be left out of the competition for wealth management of ultra-high-net-worth families from Singapore and Dubai, Hong Kong recently enacted a new tax concession regime (Inland Revenue (Amendment) (Tax...more
Partnerships are ineligible S corporation shareholders. So, a partnership cannot acquire shares in an S corporation without terminating that corporation’s S election. However, a partnership can still invest in an S...more
The UK qualifying asset holding company (“QAHC”) tax regime came into force on 1 April 2022. The regime provides a generous relaxation of certain UK tax rules for UK resident investment vehicles meeting certain eligibility...more
Introduction The UK’s new Qualifying Asset Holding Company Regime (the “QAHC Regime”) comes into effect on 1 April 2022. The main objective of the regime is to make the UK a more desirable jurisdiction from which funds (which...more
On 10 February 2022 HM Treasury published a response document (Response) to its January 2021 ‘call for input’ on a review of the UK funds regime. The review was necessarily wide-ranging, covering direct and indirect tax,...more
Look out, Luxembourg – the UK is on the verge of a set of preferential tax treatments sure to attract asset holding companies. Our Finance Group highlights what it means for the UK investment funds industry and real estate...more
The structure is a simplified version of how a typical European fund might be established in Luxembourg where currently we would typically use a downstream Luxembourg SARL or securitisation vehicle as the intermediate...more
Draft legislation for Finance Bill 2022 (the "Bill") was published on 20 July 2021. One of the main pieces of draft legislation included in the Bill is the introduction of a new tax regime for asset holding companies (the...more
HM Treasury call for input on review of UK funds regime - HM Treasury has published a call for input on its review of the UK funds regime, covering tax, relevant areas of regulation and opportunities for reform....more
- As of January 1, 2021, Luxembourg is set to disallow otherwise tax deductible interest or royalty expense for payments made to entities resident in EU blacklisted jurisdictions that qualify as a beneficial owner “related”...more
This briefing summarises the key announcements in the Spring Budget from a funds perspective: including the UK funds review, the SDLT surcharge for corporate and individual non-resident purchasers of UK residential property...more
In the recent case of Melford Capital General Partner Ltd v HMRC, the FTT concluded that a UK GP was entitled to full recovery of input VAT incurred on the establishment and operational costs of a UK LP Fund of which it was...more
In Ace Decade Holdings Ltd. v. UBS AG, No. 653316/2015, 2016 BL 413780 (N.Y. Sup. Ct. Dec. 7, 2016), Justice Eileen Bransten of the Commercial Division dismissed a $500 million fraud suit brought by an investment holding...more