Fund manager remuneration
Individuals who work for fund managers are subject to specific tax regimes in both the UK and US.
We have deep expertise advising on these matters including the specific requirements in both countries for carried interest, coinvestment and management equity to be eligible for capital gains treatment, and the application of the UK “disguised investment management fee” anti-avoidance rules.
Individuals who are subject to both UK and US taxes (such as Americans living in the UK or UK individuals working for a US-based fund manager) are subject to a real risk of double taxation due to mismatches between the UK and US treatment of the income/gains as well as timing mismatches. Our tax partners have worked with fund managers of all sizes to identify and solve double taxation problems.
We can assist with tax compliance, ensuring the fund managers are comply with both UK and US reporting rules.
In addition, we can also advise on issues arising in other jurisdictions, calling on the expertise of member firms in the Andersen Global association.