Carried interest holders (carryholders) who are US citizens or green card holders resident in the UK were left uncertain on the route to offsetting double taxation on carry when guidance was changed in early 2022 to close the door on offset against tax in this country. A new accruals basis election in the Spring Finance Bill should make it easier to claim double tax credits in the other direction, i.e. in the US. The proper administration of the elective basis may require significant liaison between the carryholder and the investment house.
If you are not a subscriber, subscribe now to read this content.
Carried interest holders (carryholders) who are US citizens or green card holders resident in the UK were left uncertain on the route to offsetting double taxation on carry when guidance was changed in early 2022 to close the door on offset against tax in this country. A new accruals basis election in the Spring Finance Bill should make it easier to claim double tax credits in the other direction, i.e. in the US. The proper administration of the elective basis may require significant liaison between the carryholder and the investment house.
If you are not a subscriber, subscribe now to read this content.
.tmb-editorspic.jpg?sfvrsn=df04ab27_1)
