A UK resident non-domiciled fund manager has asked whether the remittance basis applies to his carried interest in light of the significant changes introduced by the July 2015 summer Budget FA 2015 and FA 2016.
Answer
Typical fund structure
The typical structure employed by non-dom fund managers pre-July 2015 was as follows:
The fund manager/investment advisor would establish either a UK LLP or UK limited company that he and others would own.
The fund itself would typically include one or more tax transparent partnerships.
The fund vehicle would comprise a vehicle that qualifies for a participation exemption for dividends and capital gains.
The fund manager/investment advisor would receive: a management...
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:
A UK resident non-domiciled fund manager has asked whether the remittance basis applies to his carried interest in light of the significant changes introduced by the July 2015 summer Budget FA 2015 and FA 2016.
Answer
Typical fund structure
The typical structure employed by non-dom fund managers pre-July 2015 was as follows:
The fund manager/investment advisor would establish either a UK LLP or UK limited company that he and others would own.
The fund itself would typically include one or more tax transparent partnerships.
The fund vehicle would comprise a vehicle that qualifies for a participation exemption for dividends and capital gains.
The fund manager/investment advisor would receive: a management...
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:
