James McCredie (Macfarlanes) reviews a hugely welcome new regime, but explains there are still some ‘shoot in foot’ opportunities that it is to be hoped the government and HMRC will resist.
Fans of the asset holding company regime will already be familiar with the first and second stage consultations which have preceded this latest publication. For the benefit of other readers the use of asset holding companies by investment funds and institutional investors has long been a fixture of investment structuring for a number of tax and non-tax reasons.
Most private funds (both private equity and other asset classes) tend to be structured as tax transparent limited partnerships formed to pool investment from (largely institutional) investors. These funds then go out and acquire assets but they almost uniformly do so through a company in order to provide a liability shield (you don’t want your precious fund limited...
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James McCredie (Macfarlanes) reviews a hugely welcome new regime, but explains there are still some ‘shoot in foot’ opportunities that it is to be hoped the government and HMRC will resist.
Fans of the asset holding company regime will already be familiar with the first and second stage consultations which have preceded this latest publication. For the benefit of other readers the use of asset holding companies by investment funds and institutional investors has long been a fixture of investment structuring for a number of tax and non-tax reasons.
Most private funds (both private equity and other asset classes) tend to be structured as tax transparent limited partnerships formed to pool investment from (largely institutional) investors. These funds then go out and acquire assets but they almost uniformly do so through a company in order to provide a liability shield (you don’t want your precious fund limited...
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:
