The taxation of non-domiciled individuals and offshore trusts is a deeply complex area that is traditionally the preserve of private client advisers, says Chris Moorcroft, partner at law firm Harbottle & Lewis. Of equal complexity is the topic of private equity tax, which incorporates the Disguised Investment Management Fund (DIMF) rules and is the preserve of an equally specialist (but usually separate) set of private equity tax experts. Where the two areas interact, such as in the case of offshore trusts which hold carried interest rights, misunderstandings pervade. This article ...
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