Funds Advisory

HEDGE FUNDS

Accounting and tax treatment of the use of financial derivatives. Trading versus investing in relation to funds asset classes i.e. equities, fixed Income, real estate and commodities. Capital and/or income treatment. See also Offshore Funds

OFFSHORE FUNDS

Product Development Fund set up. Advising on locations to attract target retail and/or institutional investors. Benefits of UK reporting fund regime - other reporting fund regimes e.g. Germany – and/or institutional investors and fit in with the commercial aims and existing group structure of fund managers

ONSHORE FUNDS

Tax and regulatory treatment of UK authorised investment funds including access to the HMRC white list on trading versus investing in relation to the funds asset classes

PROPERTY FUNDS

PAIFS - Structuring and tax advice in relation to the establishment of UK property authorised investment funds and the implications of access and feeder funds for particular investor types together with the treatment of seeding capital and corporate investors. Structuring and tax advice on bringing offshore property funds onshore

REITS - Structuring and tax advice in relation to the establishment of UK real estate investment trusts

DOUBLE TAX TREATIES

Access to applicable double taxation treaties for onshore and offshore funds including property and hedge funds. Bringing attention of fund managers to the latest developments in respect of reduction of withholding tax on portfolio income and treatment of any capital gains tax

EU DEVELOPMENTS

EU UCITS Directives UCITS III and IV products together with cross border VAT issues

INVESTMENT TRUSTS

The commercial benefits of the UK tax modernisation programme

TAX COMPLIANCE AND REPORTING

Particular jurisdiction needs

FUNDS GOVERNANCE

Composition and skill sets of the Funds Board, Management and administration including custody of the Funds assets

FOREIGN REGISTRATION

Particular jurisdiction needs