Our funds practice delivers a streamlined and co-ordinated
service to our clients. The funds tax group provides an integral
part of this service.
Tax neutrality for investors and tax efficiencies for management
are vital to a fund's success. We work closely with our
clients and colleagues to understand the commercial objectives of
the fund and its participators' profiles. This allows us to
identify the most suitable investment vehicle and management
structure for each fund.
Our tax capabilities go further than fund formation. We
also regularly advise on the tax implications of realisations made
by funds, the acquisition and disposal of fund management
businesses, carried interest arrangements and the tax efficient
reconstruction, relocation or winding up of fund structures.
Our extensive experience spans all the principal types of onshore
and offshore fund, as well as joint venture, co-investment and
carried interest vehicles.
We regularly advise on the tax issues relevant to private equity
and venture capital funds, real estate funds, infrastructure funds,
renewable energy and cleantech funds. Given our unrivalled
knowledge of the film industry, we are also uniquely placed to
advise on the tax implications of investment funds in that
sector.
The summaries set out below provide a flavour of our
experience in funds tax:
- Advised on the launch of a Cypriot based clean
energy fund targeting €250m of commitments.
- Advised on the launch of an energy and
infrastructure fund seeking $500m of commitments, which used an
English LLP as the fund vehicle.
- Advised on the structuring of a fund focused on
expansion stage and late stage businesses, LMBOs and LMBIs,
targeting €250-350m of commitments.
- Advised Mourant on the sale of Mourant
International Finance Administration (MIFA), a provider of
off-shore legal and administration services for alternative
investment industries with $170 billion in assets under
administration, to US bank, State Street Corporation.
- Advised clients of F&C REIT Asset Management
LLP and AREA on the establishment of multiple Guernsey limited
partnerships for the purposes of acquiring over 220 properties from
the administrators and administrative receivers of the Dawnay Day
group.
- Advised the management of Delancey Real Estate
Asset Management in connection with the establishment of DV4
Limited, a property investment fund, which raised in excess of £1
billion.
- Advised New Star Asset Management Group PLC and
funds managed by it, in relation to its capital restructuring, the
winding-up and roll over of assets, and on a number of transactions
and operational issues.
- Advised Freedom Acquisition Holdings, Inc on the
reverse takeover of GLG Partners LP, then, Europe's largest
privately held hedge fund manager, with approximately US$18 billion
under management.
- Advised upon the establishment of a $150 million
fund for Anton Capital Entertainment which then entered into the
first European film slate financing deal in Europe with Studio
Canal.
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