Further to the successful course on the Principles of International Tax Planning which Roy undertook for 60 UBS lawyers in 2005 (which was the forerunner of “Principles of International Tax Planning” which IFS wrote and published in 2007), UBS asked IFS to assist them in the creation and implementation of an $8 billion global real estate fund, where 40% of the assets were to be in the US, 15% in Japan, 15% in continental Western Europe and 15% in the UK. With a mixture of investments with private and public funds, IFS was requested to devise generic models for such investments which would minimise tax leakage and maximise after tax returns.
Since then IFS has been involved in the creation and structuring of over 30 Private Equity Funds, looking at each new fund structure on its own merits using a “top down” approach, paying particular attention to the investor profile and tax status, and a “bottom up” approach paying particular attention to the assets in which the fund is to invest and how these should be properly for tax mitigation purposes.
Although many of the Private Equity Funds have been real estate related, including those for Berlin, Rumania, Bulgaria and many other Eastern European countries, several of these funds have been involved in such diverse businesses as fine art, film finance, shipping and aviation.
We understand the regulatory requirements in various jurisdictions including the Channel Islands, Isle of Man, Luxembourg and Cyprus amongst others. Through our network of colleagues worldwide, we are able to assist with the implementation of such funds.