Relief for double taxation of carried interest now needs to be found on the other side of the Atlantic. The new accruals regime helps to make this possible, write Eli Hillman and Linus Ostberg (KPMG).
Firstly a quick recap on carried interest of a high-level nature. Private equity and certain other private capital fund structures have traditionally provided a special financial return to team members/carryholders in the form of an entitlement to the super-profits of the fund.
Under typical carried interest terms once invested capital has been distributed back and commonly a fixed or ‘preferred’ return usually 8% cumulative per annum has been paid to the external investors then (generally after a ‘catch-up’...
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Relief for double taxation of carried interest now needs to be found on the other side of the Atlantic. The new accruals regime helps to make this possible, write Eli Hillman and Linus Ostberg (KPMG).
Firstly a quick recap on carried interest of a high-level nature. Private equity and certain other private capital fund structures have traditionally provided a special financial return to team members/carryholders in the form of an entitlement to the super-profits of the fund.
Under typical carried interest terms once invested capital has been distributed back and commonly a fixed or ‘preferred’ return usually 8% cumulative per annum has been paid to the external investors then (generally after a ‘catch-up’...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")