A&M Taxand Webinar 12 May 2021: Virtual Asset Manager Roundtable 

On 12 May 2021, we hosted the third London Virtual Asset Manager Roundtable event covering the following presentation topics:

•    Market update provided by Daniel Parry, Managing Director and Head of Funds Tax;
•    Update on the Disguised Investment Management Fee rules provided by Daniel Parry;
•    Overview of HM Revenue & Customs (“HMRC”) enquiries into the tax treatment of carried interest provided by Shirley Ly, Associate Director; and
•    Guest presentation by IQ-EQ on Environmental, Social and Corporate Governance.

If you missed the webinar, please download a copy or listen to a recording of the presentation.

Overview of U.K. commentary on recent U.S. tax changes

U.S. President Joe Biden delivered news of impending U.S. tax increases in a speech to a joint session of U.S. Congress in late April. 

The key tax highlights include:

•    Closing of the “carried interest loophole” and eliminating the tax benefit for certain taxpayers. 
•    A reintroduction of the 39.6% top tax rate (more than $400,000) for individuals.
•    A new provision which will tax individual's Long-Term Capital Gains and Qualified Dividends (for those with ‘income’ over $1m) at the top rate of tax (39.6% proposed). Net Investment Income Tax (“NIIT”) would also apply, taking the overall rate to a potential 43.4%.
•    A new Internal Revenue Service focusing on the tax affairs of the wealthy. 
•    An increase in the corporation tax rate from 21% to 28%. It should be remembered that state corporate taxes are in addition.

Employment Related Securities ("ERS") reporting reminder for 6 July 2021

We wanted to provide another reminder that following the end of the 2020/21 U.K. tax year, annual ERS returns should be submitted to HMRC by 6 July 2021. 

The ERS annual return will report any new or existing share plans (including co-investment and carried interest entitlements) to HMRC for 2020/21 and involves a number of key tasks, including:

•    Registering new share plan arrangements;
•    Verifying or self-certifying the tax-advantaged plans in place; and
•    Submitting annual returns with all reportable events (including nil returns).

All ERS annual returns should be filed with HMRC on or before 6 July 2021 for the tax year 2020/21, with late filings resulting in an automatic penalty and potentially significant consequences for tax-advantaged plans.

If you need any assistance or if you are unsure whether you are required to file an ERS annual return for 2020/21, please don’t hesitate to get in touch.

Introduction to new A&M Taxand Financial Investors team members

A&M Taxand has strengthened its tax advisory practice appointing Nick Walton, Jack Hollyman and John Bettley-Smith as Senior Directors within its Financial Investors team. 

The hiring of Mr. Walton, based in Manchester, and Messrs Hollyman and Bettley-Smith, based in London, extends A&M Taxand’s U.K. capabilities and geographic footprint into Manchester, demonstrating the firm’s commitment to meeting the market’s evolving needs.

Prior to joining A&M Taxand, Messrs. Bettley-Smith, Hollyman and Walton served as Directors in Deloitte’s M&A and Funds Tax group where they advised key private equity and infrastructure clients on acquisitions, restructurings, and disposals. They each have extensive expertise solving for merger & acquisition (M&A) tax concerns in the infrastructure asset class and for corporate and international tax issues.

In addition to the firm’s Manchester office, which opened in 2018, A&M has U.K.-based offices in London, Birmingham, Leeds and Glasgow.

COVID-19 and AGM 2021 insights: Did companies listen on executive pay?

The first 50 U.K. annual general meetings (“AGM”) of 2021 have now taken place with organisations continuing to seek a path to recovery out of the pandemic in 2020, with many having furloughed employees or accepted other government support.
A&M’s Executive compensation team have explored the executive remuneration decisions taken by such and the resultant remuneration trends for 2021.
Read the full report on our website.