US/UK Fund Clients

Carried interest and co-invest awards and taxation

We advise fund management businesses on the award and taxation of co-invest and carried interest. At the outset it is critical to determine whether any of the intended recipients are US taxpayers. Where US taxpayers are involved, our specialist funds team can advise on the US tax treatment and on the requirement to make US tax elections on receipt of carried interest and co-invest.

Tax projections and UK and US pre-arrival tax planning

We prepare tax projections for US taxpayers on their carried interest and co-invest, factoring in the availability of foreign tax credits for UK taxes and identifying potential pitfalls that might lead to double taxation if not proactively addressed. We also advise on pre-arrival tax planning considerations for fund executives who are either US citizens about to commence work in the UK or for UK citizen executives on secondment/permanent transfer to the US.

Complex tax compliance and tax credit management

The interaction of the US and UK tax treatment of carried interest and co-investment returns is complex for both US citizens who are UK tax resident and UK citizens with US fund interests. Our funds team are delighted to help with US/UK tax return preparation, support with appropriate tax return disclosures and proactive management of foreign tax credits to mitigate the risk of double taxation.

To meet our US/UK Private funds team, get in touch with one of the senior leaders below. We would be delighted to talk to hear from you.