Coming Onshore – are Investors better off when Offshore Property Funds Convert to REIT status?

 Investment Tax, Property Tax, REITs  Comments Off on Coming Onshore – are Investors better off when Offshore Property Funds Convert to REIT status?
Feb 162015
 

Shortly before Christmas last year, the financial press reported that the Guernsey investment company F&C UK Real Estate Investments – F&C for short – was planning to “come onshore” and convert to a UK REIT. This is just the latest of a number of closed ended property funds based in the Channel Islands that have taken this step, Standard Life being another well know name to make the change (or to give it its full name, Standard Life Investments Property Income Trust).

What does it mean to “come onshore” and why are these funds doing it now? In the following article, we shall explain the consequences of converting to a REIT, and in particular ask the question “How does it benefit investors?” Continue reading »

Venture Capital Trusts Part Four – What does the investment portfolio look like?

 Investment Tax, Venture Capital Schemes  Comments Off on Venture Capital Trusts Part Four – What does the investment portfolio look like?
Sep 042014
 

This is the fourth in our series of articles on venture capital trusts.

(This article can be downloaded in pdf format in portrait or landscape version at Academia.edu.)

In this article, we shall be exploring the conditions that describe what the portfolio looks like “on the outside” – the rules governing the type of investments that can be made, the way in which the company’s income must be distributed, and how much of the portfolio must be invested in the riskier class of assets that are the basis of the Venture Capital Scheme.

Continue reading »

Jul 152014
 

Following this year’s Budget, the Government published a Consultation Paper on its plan to bring non-residents within the charge to capital gains tax on residential property. This article discusses the proposal, with a particular emphasis on what this means for offshore investment funds. Continue reading »

Real Estate Investment Trusts – What do they invest in? Part One – Bricks and Mortar

 Investment Tax, Property Tax, REITs  Comments Off on Real Estate Investment Trusts – What do they invest in? Part One – Bricks and Mortar
Jun 272014
 

This is the first of two articles where we take a closer look at the type of asset that goes into a REIT’s property portfolio. While the answer is perhaps obvious (property of course!), there are certain restrictions that wouldn’t normally apply to other commercial landlords. Furthermore, it isn’t so obvious that a REIT can hold property indirectly through other investment vehicles such as unit trusts, OEICs and partnerships.

In this article we shall concentrate on the type of direct investments that one would expect to see in a property portfolio – the bricks and mortar. Indirect investments will be the subject of the next article. Continue reading »

Jan 202014
 

This is the third in our series of articles on venture capital trusts. In this article we shall look at the conditions relating to the VCT itself. In particular, we shall look at the way the VCT is structured as opposed to the way in which the business is run, or the conditions attached to the investments in the underlying portfolio. These topics are the subject of future articles in this series.

(This article can be downloaded in pdf format in portrait or landscape version at Academia.edu.)

Continue reading »

Dec 192013
 

One of the welcome changes in the recent Autumn Statement is the classification of a REIT as an institutional investor for the purpose of the “close company” test. This will hopefully make it easier for REITs – both foreign and domestic – to invest in other REITs.

Continue reading »

Nov 152013
 

In our introductory article on REITs, we looked at how the underlying property rental business is taxed, and how the tax position of the fund is effectively transferred to the investors.

In particular, we saw that there is no tax, both on income profits and capital gains at the fund level. The profits are taxed as property income when distributed to the shareholders, while capital gains accrue in the fund, and are only taxed when the shareholders realise their investment.

But what does it take to be a REIT and to qualify for the tax breaks? This is the topic that we explore in this article. Continue reading »

Venture Capital Trusts Part Two – Who are the investors?

 Investment Tax, Venture Capital Schemes  Comments Off on Venture Capital Trusts Part Two – Who are the investors?
Nov 062013
 

This is the second in a series of articles on venture capital trusts. In Part One we looked at the tax breaks on offer for those brave enough to risk their capital. In this article we shall take a closer look at the investors – who they are, how they can invest, and what are the strings attached to the investment.

(This article can be downloaded in pdf format in portrait or landscape version at Academia.edu.)

Continue reading »

An Introduction to Real Estate Investment Trusts

 Investment Tax, Property Tax, REITs  Comments Off on An Introduction to Real Estate Investment Trusts
Oct 252013
 

A Real Estate Investment Trust – or REIT for short – is a property investment company which pays no tax on the income and capital gains derived from its rental assets. Instead, the tax is effectively transferred to the shareholders, who are treated as if they had invested directly in the underlying properties.

In this introductory article, we shall look at how the tax legislation achieves this result. We shall go on to look at other aspects of the REIT regime in subsequent articles.

Continue reading »

Sep 032013
 

Share buybacks are an attractive way in which VCT investors can realise their investment. However, HMRC is concerned that this technique is also being used to access another round of tax relief, without necessarily supplying new cash to the businesses for which the scheme was intended to benefit.

So what is the problem, and what is the Government proposing to do about it? Continue reading »