James Burton, Naomi Lawton & Sorsha Reilly (Allen & Overy) provide a practical Q&A on the workings of the new regime that is designed to offer significant benefits to attract a wide range of investors and holding structures.
1. Why do we need a new regime and how did we get here?
Most alternative investment funds will comprise a main fund vehicle into which investors will pool their capital (sometimes through other ‘feeder’ vehicles). The fund itself may take many forms but it is most commonly established as a tax transparent limited partnership. In addition the fund will typically have a number of special purpose vehicles sitting underneath the fund itself performing various holding functions. These holding vehicles are important as they help to silo and segregate risks and liabilities allow for ring-fenced financing and hedging and enable the fund to provide equity incentives...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
James Burton, Naomi Lawton & Sorsha Reilly (Allen & Overy) provide a practical Q&A on the workings of the new regime that is designed to offer significant benefits to attract a wide range of investors and holding structures.
1. Why do we need a new regime and how did we get here?
Most alternative investment funds will comprise a main fund vehicle into which investors will pool their capital (sometimes through other ‘feeder’ vehicles). The fund itself may take many forms but it is most commonly established as a tax transparent limited partnership. In addition the fund will typically have a number of special purpose vehicles sitting underneath the fund itself performing various holding functions. These holding vehicles are important as they help to silo and segregate risks and liabilities allow for ring-fenced financing and hedging and enable the fund to provide equity incentives...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
