Sovereign wealth fund investments in private funds: selected tax planning considerations in the US, EU and UK

2021 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Daniel A. Nelson ◽  
Kate Habershon ◽  
Kathryn W. Hambrick ◽  
Meghan E. McCarthy ◽  
Alexios S. Hadji ◽  
...  

Purpose To discuss US, EU and UK tax-related issues that sovereign wealth funds should consider when investing in private funds. Design/methodology/approach Discusses various tax-related structuring, operational, risk-allocation, and economic matters that private funds, sovereign wealth funds and other non-US institutional investors should consider a series when evaluating potential private fund investments. Findings Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds in 2020 and, as the world emerges from the pandemic, are expected to make similar or greater commitments in 2021 and beyond. Originality/value Practical guidance from lawyers with wide experience in international tax planning and investment fund structuring.

2015 ◽  
Vol 28 (1/2) ◽  
pp. 70-76 ◽  
Author(s):  
Mike McGrath

Purpose – The purpose of this paper is to consider the changes that have taken place in Interlending & Document Supply over the past 12 years. Design/methodology/approach – Research of the past 48 literature reviews published in Interlending & Document Supply. Findings – Over the past 12 years, Interlending & Document Supply has declined dramatically in much of the world, although less so in the US. It is likely to increase in the developing world but not as much as to compensate for the decline elsewhere. Originality/value – This is the only study that has been made of the changes in document supply in this century.


2018 ◽  
Vol 19 (3) ◽  
pp. 39-41
Author(s):  
Anne-Marie Godfrey ◽  
Stuart Leblang ◽  
Ron Grabov-Nardini ◽  
Monte Jackel

Purpose This paper aims to explain how the Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, changes the way the US Internal Revenue Service will conduct audits of collective investment vehicles treated as partnerships for US tax purposes. Design/methodology/approach This study explains the entities covered by the new partnership audit regime, the effective dates of the new regime and steps to be taken by funds covered by the new audit regime. Findings The results show that the new regime creates a liability at the partnership level for any unpaid tax, placing the tax burden on current-year partners. Practical implications A fund manager should determine whether the new audit regime is applicable to any of the funds he or she is managing and, if so, amend the fund documents to accommodate the new audit rules, providing a mechanism to elect and supervise a partnership representative, a mechanism to allocate the economic burden of the tax to the appropriate partners and a procedure for selecting the method to calculate the amount of the fund’s tax liability attributable to an audit. Originality/value This study provides practical guidance from experienced investment, fund and tax lawyers.


2020 ◽  
Vol 36 (8) ◽  
pp. 29-31

Purpose Reviews the latest management developments across the globe and pinpoints practical implications from cutting-edge research and case studies. Design/methodology/approach This briefing is prepared by an independent writer who adds their own impartial comments and places the articles in context. Findings The problem with developing a reputation of being something of an oracle in the business world is that all of a sudden, everyone expects you to pull off the trick of interpreting the future on a daily basis. Like a freak show circus act or one-hit wonder pop singer, people expect you to perform when they see you, and they expect you to perform the thing that made you famous, even if it is the one thing in the world you don’t want to do. And when you fail to deliver on these heightened expectations, you are dismissed as a one trick pony, however good that trick is in the first place. Originality/value The briefing saves busy executives and researchers hours of reading time by selecting only the very best, most pertinent information and presenting it in a condensed and easy-to-digest format.


2018 ◽  
Vol 19 (4) ◽  
pp. 1-3
Author(s):  
Robert Van Grover

Purpose To summarize and interpret a Risk Alert issued on April 12, 2018 by the US SEC’s Office of Compliance Inspections and Examinations (OCIE) on the most frequent advisory fee and expense compliance issues identified in recent examinations of investment advisers. Design/methodology/approach Summarizes deficiencies identified by the OCIE staff pertaining to advisory fees and expenses in the following categories: fee billing based on incorrect account valuations, billing fees in advance or with improper frequency, applying incorrect fee rates, omitting rebates and applying discounts incorrectly, disclosure issues involving advisory fees, and adviser expense misallocations. Findings In the Risk Alert, OCIE staff emphasized the importance of disclosures regarding advisory fees and expenses to the ability of clients to make informed decisions, including whether or not to engage or retain an adviser. Practical implications In light of the issues identified in the Risk Alert, advisers should assess the accuracy of disclosures and adequacy of policies and procedures regarding advisory fee billing and expenses. As a matter of best practice, advisers should implement periodic forensic reviews of billing practices to identify and correct issues relating to fee billing and expenses. Originality/value Expert guidance from experienced investment management lawyer.


2018 ◽  
Vol 119 (1/2) ◽  
pp. 87-93 ◽  
Author(s):  
Claire Creaser

Purpose Library impact and how to evaluate it has been debated for a number of years. While the activity – the busy-ness – of the library is now routinely measured and described, the difference the library makes is less tangible and harder to measure. Libraries in all sectors and worldwide are grappling with this issue, and the purpose of this paper is to summarise international standards available to support them. Design/methodology/approach The first international standard concerning library impact, ISO 16439 Information and documentation – methods and procedures for assessing the impact of libraries, was published in 2014 after several years in development. Findings The standard describes a range of methods for assessing library impact which have been used across the world in a variety of libraries in all sectors. Originality/value This paper summarises the key methods described in the standard, and gives references for further reading.


2017 ◽  
Vol 33 (8) ◽  
pp. 36-38

Purpose This paper aims to review the latest management developments across the globe and pinpoint practical implications from cutting-edge research and case studies. Design/methodology/approach This briefing is prepared by an independent writer who adds their own impartial comments and places the articles in context. Findings It is said that Latin America is one of the hardest places in which to do business, and within Latin America as well as considering the differing challenges that Argentina or Columbia may present, Brazil is perhaps the most difficult place to go to in order to develop trade and commercial agreements. In addition to the different language as compared to the rest of the region, there is a very specific culture and life view that will be wholly alien to many business people, whether they are from developed or developing countries around the world. Practical implications The paper provides strategic insights and practical thinking that have influenced some of the world’s leading organizations. Originality/value The briefing saves busy executives and researchers hours of reading time by selecting only the very best, most pertinent information and presenting it in a condensed and easy-to-digest format.


2016 ◽  
Vol 32 (9) ◽  
pp. 32-35
Author(s):  
Mark Thomas

Purpose The purpose of this paper is to analyze Lenovo’s successful acquisition of IBM’s PC division using Ghemawat’s (2001) CAGE framework. It was an acquisition that was so full of symbols that it is difficult to know where to begin. Lenovo’s purchase of IBM in 2005 was first seen as a sign of the rapid growth and expansion of the Chinese economy and its transformation away from the traditional manufacturing base to more high-tech areas. For doomsday merchants in the land of Uncle Sam, it foretold the end of the world domination of the US economy. Despite a considerable number of skeptics at the time, Lenovo was clearly up to the task. Such was the success of the acquisition that by 2015, Lenovo could claim to have grown into the world’s number 1 PC maker, number 3 smartphone manufacturer and number 3 in the production of tablet computers. Design/methodology/approach This paper is a case study. Findings Despite a considerable number of skeptics at the time, Lenovo was clearly up to the task. Such was the success of the acquisition that by 2015, Lenovo could claim to have grown into the world’s number 1 PC maker, number 3 smartphone manufacturer and number 3 in the production of tablet computers. Indeed, by 2014, the firm had enough confidence to add the IBM server business to its portfolio. Originality/value The briefing saves busy executives and researchers hours of reading time by selecting only the very best, most pertinent information and presenting it in a condensed and easy-to-digest format.


2021 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Ronny Alexander Zayas-Mateo ◽  
Ángel Rafael Martínez-Lorente

Purpose ISO 9001 is applied by hundreds of thousands of companies throughout the world. For this reason, its effect on company results has been extensively studied. However, the results of those studies are inconclusive and sometimes contradictory. More in-depth research, with a new approach, is therefore necessary. The purpose of this paper is to analyse whether ISO 9001-certified companies suffered the effects of the financial and economic crisis of 2007–2008 to a lesser degree than non-certified ones. Design/methodology/approach A set of 179 companies certified by ISO 9001:2008 and 154 non-certified ones were analysed, as well as the accounting figures for net sales and operating income (EBIT: earnings before interest and taxes) from 2004 to 2012. Findings Companies from the industry and services sectors showed different results. Certified industrial companies achieved better outcomes than their non-certified counterparts. However, the deviations in outcomes were not significant for services companies. Research limitations/implications One limitation of this study is that companies’ official results are not always their true results. Another limitation is that having to do with the criteria followed to suppress extreme cases, which is always subjective. Furthermore, the implications of the results could be of use for those managers who are responsible for implementing ISO 9001 and for deciding whether obtaining the ISO 9001 certification would be beneficial to their companies. Originality/value This study constitutes a new approach for the assessment of the benefits of the ISO 9001 certification.


2021 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Peter Buell Hirsch

Purpose The purpose of this viewpoint is to examine the reasons why so many employees around the world are choosing not to go back to work as the COVID-19 pandemic eases. Design/methodology/approach The viewpoint is an overview of the various viewpoints expressed on this topic and the author’s perspective on the most likely reasons and what companies can do to prevent this “discontent” from spreading. Findings Companies need to carry through on their newfound commitment to citizenship and purpose beyond shareholder value to find a new capital/labor equilibrium. Originality/value While individual views on this topic have been covered, this is a comprehensive perspective and recommendation on dealing with the issue.


2021 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Louise Livingstone

Purpose The paper aims to rediscover the subtle heart and discuss its importance in relation to conversations regarding sustainability. Design/methodology/approach Based on the imaginal approach of the author’s doctoral research, this paper is informed by the discourse of transpersonal psychology, attempting to open a space through which it becomes possible to perceive the heart differently. Findings This paper discusses the idea that knowledge as generated through the heart has been rendered subservient to knowledge generated through the mind/brain through a dominant/medical narrative (Bound Alberti, 2012). This means that the heart’s wisdom and the heart’s benevolent qualities cannot gain traction at the level at which decisions are made in society. Research limitations/implications While the heart is not unproblematic, and can carry notions of moral superiority, this paper is written as an appeal to create safe enough spaces to bring the heart back into conversation at the level of political discourse. Practical implications This paper suggests that it is the approach of the heart, the qualities and characteristics that the heart embodies, and the different way of being in the world that the heart makes possible, which could play an important role in guiding us towards a more sustainable world. When taken seriously, the heart offers a way of engaging with, and thinking about, ideas of relationship, wholeness and interconnection – all of which have been identified as important by numerous scholars in relation to engaging with global challenges (de Witt, 2016). Social implications This paper suggests that it is the approach of the heart and the different way of being in the world that the heart makes possible, which could play an important role in guiding humanity towards a more sustainable world. Originality/value Since the late 1900s, scholars have been calling for creative thinking in relation to engaging with the myriad of issues facing our planet, and this paper is written as a response to that call – creating a platform for the heart to speak and making a case for its importance in conversations relating to sustainability.


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