• The details
  
• Illustrated with case study calculations

Chair

David Goy QC
Gray’s Inn Tax Chambers

 

Speakers

Caroline Kemp
Tax Senior Manager: Real Estate Advisors
KPMG LLP

Ashleigh Kewney
Head of Tax
Henderson Group plc

Hugo Llewelyn
Head of Investment
Protego Real Estate

Lorraine Parkin
Partner
RSM Robson Rhodes LLP

Malcolm Powell
Senior Manager
RSM Robson Rhodes LLP

Richard Ross
Partner: Real Estate Advisors
KPMG LLP

Rosalind Rowe
Real Estate Tax Director
PricewaterhouseCoopers

Richard Woolich
Head of Tax
Kirkpatrick & Lockhart
Nicholson Graham LLP

 

Scenarios to be covered during the day include:

Onshore

UK Investment Trust
• Listed company
• Requirements of section 842 ICTA 1988
• Taxation in investment trust subsidiary
• Investment trust exempt from tax on chargeable gains

UK Authorised Investment Funds
• OEICs and Authorised Unit Trusts (AUTs)
• Daily pricing/liquidity
• Changes arising from the COLL Sourcebook
• AIFs exempt from tax on chargeable gains

UK Exempt Unauthorised Unit Trust
• UK tax exempt investors only
• Frequent pricing/liquidity
• Typically used by pension funds and charities
• Pensions Act changes may make UUT unnecessary

UK Limited Partnerships
• Tax transparent
• Investors are limited partners
• Unlisted, more flexible
• SDLT on changes in partners

UK REIT – where are we now?
• March 2005 discussion paper
• Potential legal form and taxation treatment
• Outstanding issues
• Potential users

Offshore

Syndicates
• Investment in single property
• Offshore company
• Normal company tax rules will apply in offshore jurisdiction

Offshore Unit Trusts
• Baker Trust – income tax transparent
• Capital Gains Tax - opaque
• Residence issues
• VAT
• Cost of administration
• SDLT – seeding relief
• UK non-resident landlord issues
• Regulation

Offshore Investment Companies
• May be listed or unlisted
• UK non-resident landlord issues
• Regulation

Others

Limited Liability Partnerships (LLPs)
• Corporate structure, but taxed as a partnership
• Income and gains received by tax exempt entities is taxable
• SDLT on changes in partners

Partnerships
• Unlimited liability as a partnership
• Income and gains directly attributable to partners
• SDLT on changes in partners