Carried interest: Millican unCheyned

Andrew Howard

Omar Asfar

Andrew Howard and Omar Asfar (Ropes & Gray) examine a case about whether an individual who is not a fund manager can be taxed under the carried interest rules.

The recent decision in N Millican v HMRC [2024] UKFTT 618 (TC) is a case about whether an individual who is not a fund manager can be taxed under the carried interest rules.

Real estate joint venture

The transaction in question was a typical real estate investment joint venture with one party (Cheyne Funds) providing most of the money and the other party (Greycoat) performing the operating partner role with greater responsibility for finding and running the deal. As is typical if the deal was successful the operating partner stood to benefit from a promote (a share of the deal proceeds to reward its role in the deal outsized compared to the cash investment it made)....

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Andrew Howard and Omar Asfar (Ropes & Gray) examine a case about whether an individual who is not a fund manager can be taxed under the carried interest rules.

The recent decision in N Millican v HMRC [2024] UKFTT 618 (TC) is a case about whether an individual who is not a fund manager can be taxed under the carried interest rules.