Fund Formation
Our team applies market knowledge and legal, tax and regulatory technical expertise to advise fund managers on the full range of tax and structuring matters relating to investment funds.
Our range of services includes:
- acting for sponsors on the structuring of the full range of investment funds across a range of asset classes;
- acting on the establishment of investment holding platform below fund structures; and
- working with sponsors to design bespoke investment products for separate managed accounts and non-blind pool arrangements.
Most of the funds we establish are outside the UK and we design structures attractive to investors globally. We have significant experience structuring for investors sensitive to regimes including: ERISA, Solvency II, Canada’s Pension Benefits Act, US PFIC and CFC rules, UK non-domiciled remittance rules and the Australian CFC rules. The fund structure we design also takes account of tax developments including BEPS, ATAD I + II and related issues.
