Perhaps inevitably, there are some modifications to the new regime.
The ownership condition continues to present the biggest challenge to accessing the QAHC regime – both in terms of sheer complexity and application to less than straightforward cases. It is no surprise that the government has needed to return to this part of the rules to make some improvements.
We have seen in practice a number of deficiencies with the existing rules that have prevented fairly standard arrangements from qualifying.
The rules have been particularly difficult for parallel partnerships and aggregator funds for no apparent reason other than for the fact it was too late to make changes during the initial drafting cycle. The rules prevented a series of parallel partnerships from qualifying where one satisfied the genuine diversity of ownership condition (GDO) but the other was not a qualifying fund. An easy fix would...
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Home >Articles > QAHC changes: further refinements
QAHC changes: further refinements
Perhaps inevitably, there are some modifications to the new regime.
The ownership condition continues to present the biggest challenge to accessing the QAHC regime – both in terms of sheer complexity and application to less than straightforward cases. It is no surprise that the government has needed to return to this part of the rules to make some improvements.
We have seen in practice a number of deficiencies with the existing rules that have prevented fairly standard arrangements from qualifying.
The rules have been particularly difficult for parallel partnerships and aggregator funds for no apparent reason other than for the fact it was too late to make changes during the initial drafting cycle. The rules prevented a series of parallel partnerships from qualifying where one satisfied the genuine diversity of ownership condition (GDO) but the other was not a qualifying fund. An easy fix would...
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:
