![]() Carlisle Management Company Responds to IRS Tax RulingsJune 22, 2009 LUXEMBURG–(WiredPRNews.com Press Release Service - June 22nd, 2009) On May first, the Internal Revenue Service (IRS) issued two Revenue Rulings that constitute the official position of the IRS on certain key tax issues in the life settlement arena. Uncertainty in this area plagued taxpayers and tax practitioners for years. Due to these recent developments, Carlisle Management Company SCA, a Luxembourg based Management Company, found it prudent to clarify the tax situation of The Peninsula Life Settlement Funds FCP SIF, a Luxembourg based fund. The Peninsula Life Settlement Fund FCP SIF is an umbrella mutual investment fund organised under the laws of Luxembourg managed by Carlisle Management Company SCA. A Luxembourg FCP is considered as being a tax transparent entity in Luxembourg. A tax transparent entity is an entity which is not taxed either in representative capacity or in its own capacity as a tax paying entity, but the tax is levied on the investors, in their domicile, on their share of income in the entity. • The tax authorities of the investor’s home jurisdiction (domicile); Indeed, investors in the FCP should be no worse off as a result of pooling their investments than if they had invested directly in the relevant investments held by the FCP on their behalf. This can be achieved by the tax authorities of the investor’s domicile and the tax authorities where investments are located (USA) agreeing to apply tax treaty benefits (double taxation treaty) as if the FCP did not exist i.e. considering it as tax transparent. About Carlisle Management Company SCA Press inquiries: Carlisle Management Company Come And Visit
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