Michael Alliston

This Practice Note describes how a company may apply for HMRC approval as an investment trust for tax purposes. It covers the content necessary in an application, the procedure for making an application, and the effect of HMRC granting approval. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note looks at what happens when a company that has been approved by HMRC as an investment trust breaches any of the investment trust eligibility conditions or ongoing requirements. It considers the different types of breaches—serious breaches, minor breaches and disregarded minor breaches—including the effect of multiple minor breaches and different levels of breach of the income distribution requirement. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note considers the tax implications of a liquidation (winding-up) of an investment trust, particularly in the context of an investment trust reconstruction where investors are given the opportunity to roll-over their investment into a new investment vehicle. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note describes the tax treatment of approved investment trusts and their investors, including a consideration of the elective streaming regime. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note looks at what investment trusts are, and describes the eligibility conditions and other ongoing requirements that a company must satisfy in order to be regarded as an investment trust for UK tax purposes. It looks at the eligibility conditions dealing with spread of investment risk, admission of the company’s ordinary shares to trading on a regulated market and the requirement not to be a venture capital trust or UK real estate investment trust. It then looks at the requirements not to be close, to distribute income and to notify HMRC of any breach of the eligibility conditions or ongoing requirements, or of a revised investment policy. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note describes the consequences that follow from ‘minor’ breaches and 'serious' breaches of the requirements of the reporting fund regime, including exclusion from the regime. It also covers the situation where a reporting fund wishes to leave the reporting fund regime voluntarily. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note describes how an offshore fund applies for reporting fund status, the effect of an offshore fund entering the reporting fund regime and certain modified rules for constant net asset value (constant NAV) funds. It also describes the application process for clearance that a reporting fund, or offshore fund applying for reporting fund status, is a ‘diversely owned fund’ meaning that the fund’s transactions falling on the ‘investment transactions list’ (sometimes called the ‘white list’) are treated as non-trading transactions for the purposes of calculating the fund’s reportable income. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note looks at non-reporting offshore funds and the tax treatment of their UK investors. In particular, it examines the computation and taxation of offshore income gains (OIG) on a disposal of an interest held in a non-reporting offshore fund, as well as the tax treatment of distributions. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note describes the various ongoing obligations placed on an offshore fund within the reporting fund regime. It covers requirements relating to a reporting fund's accounting policies and the required calculation of ‘reportable income’ for each reporting period (including adjustments that need to be made for capital items, special classes of income and equalisation arrangements). It also discusses the reports that must be made available to certain investors and information that must be provided to HMRC. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.

This Practice Note describes how an offshore fund is defined for UK tax purposes. It also discusses the background to the offshore funds rules and what that legislation seeks to address. This Practice Note was produced in partnership with Michael Alliston of Norton Rose Fulbright.