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The United Kingdom has signed intergovernmental agreements (‘IGAs’) with its Crown Dependencies and Overseas Territories in order to improve compliance with UK tax laws, a regime often referred to as ‘UK FATCA’. The jurisdictions that are part of the UK FATCA regime (‘UK IGA jurisdictions’) include a number of common investment fund jurisdictions, such as Cayman Islands, Bermuda, British Virgin Islands, Guernsey, Jersey and Gibraltar. Funds located in these UK IGA jurisdictions become subject to…
In a previous post dated 8 April 2014, we described certain registration and compliance requirements for hedge funds and hedge fund managers under the US Foreign Account Tax Compliance Act (“FATCA”). On 22 April 2014, HM Revenue & Customs (“HMRC”), the UK tax authority, issued a supplementary update to its guidance on the position of UK investment advisers and investment managers under FATCA. This updated guidance clarifies that UK investment managers will generally not be required to…
In May 2013, HM Revenue and Customs (“HMRC”) consulted on proposals in two areas to tackle perceived tax avoidance via partnerships. The first area was disguised employment in Limited Liability Partnerships (“LLPs”) and the second was the tax-motivated allocation of business profits and losses in partnerships (including LLPs), especially profit allocations to the corporate member of an LLP. The consultation has ended and HMRC issued final legislative proposals and a detailed draft Technical Note and…