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Practical problems raised by the new offshore funds rules

Article (previously published in the Tax Journal) by Eloise Walker, Partner in the Tax group, discussing some practical problems raised by the new offshore fund rules.

The new offshore fund rules are well bedded in, but some practical problems are still being thrown up. Exiting shareholders now get different treatment with equalisation. The information requirements on investor vouchers seem to involve telling investors irrelevant information. How to deal with foreign currencies currently remains difficult. The recognition of income for the December 2009 to May 2011 period is causing odd effects. Investment managers and advisers are having to find their own way forward until industry pro formas and HMRC guidance on these practical problems catches up.