 |
|
|
 |
|
| |
|
| Lowtax Network Sites |
| Lowtax Network Portal:
'Low-tax' business and investment in the top 50 jurisdictions covered in
exceptional detail. |
| Tax News: Global
tax news, continuously updated through the day. |
| Investors Offshore:
The independent offshore and alternative investment guide for expatriates
and the globally aware investor. Sponsored by HSBC
Bank International. |
| Law & Tax
News: Daily news and background data on tax and legal developments
for international business. |
| Offshore-e-com:
A topical guide to offshore e-commerce focused on tax and regulation. |
| Lowtax Library:
One of the web's largest and most authoritative business and investment
information sources. |
| US Tax Network:
The resource for free online US taxation information, covering: corporate
tax, individual tax, international tax, expatriates, sales and e-commerce
tax, investment tax. |
| Personal
Business Tax Guide: Providing essential tax news and information
on business for contractors, entrepreneurs, professionals, small businesses,
artists, sportspersons and entertainers. |
| Offshore Trusts
Guide: OTG publishes news, features and newsletters on the use of
offshore trust structures. |
| TreatyPro: Online
tax treaty resource. |
|
|
| Better Capital Funds Employ Unique Guernsey Structure |
by Jason Gorringe, Tax-News.com, London
Tuesday, January 31, 2012
Carey Olsen and Heritage International Fund Managers Limited have acted for Better
Capital Limited, an existing Guernsey closed-ended fund listed on the London Stock
Exchange (LSE), on its innovative conversion into a uniquely-structured protected cell company.
The conversion will facilitate the launch of a second fund, the Better Capital
Fund II, with funding allocated under a 2012 cell, separate from the interests of
the existing fund, and associated 2009 cell.
This is the first example of a closed-ended PCC with more than one cell having
a full LSE listing. The innovative use of a PCC structure provides operational
efficiencies and is also designed to separate the new portfolio of assets to
be acquired by Fund II from the existing portfolio, thus providing enhanced
shareholder benefits.
The 2012 cell has raised GBP169.9m (USD266m) of new money to invest in Better Capital
Fund II. The new money was raised under a placing and an open offer to existing
shareholders. Like the 2009 cell, the 2012 cell will invest principally in UK
and Irish turnaround opportunities.
The use of a PCC in this way is also pioneering for private equity structuring
as it provides the company with the scope to continue to raise further funds
in distinct cells, as well as providing the legal segregation of assets and
their allocation to each shareholder vintage through a clear separation of listed
share classes.
From an operational stance, the unique aspects of the PCC structure reduce
running expenses and enable strong corporate governance, as a single board of
directors has oversight over the distinct fund vintages.
The team from Carey Olsen included corporate partner Tom Carey, who said: “The use of the PCC structure to create separate
listed portfolios enables new money to be raised without diluting the existing
portfolio and without complicating shareholder distribution rights at the end
of the life of the original portfolio. Successive portfolios can be created,
each being at a different stage in their lifespan and each benefiting from the
experience of a single Board.”
A comprehensive report in our Intelligence Report series
giving a country-by-country analysis of offshore investment funds, stock exchanges
and trusts, with an analysis of the US QI regime, is available in the Lowtax
Library at http://www.lowtaxlibrary.com/asp/subs_reports.asp
and a description of the report can be seen at
http://www.lowtaxlibrary.com/asp/description_report9.asp
|
|
|
|
| THE LOWTAX LIBRARY
One of the web's largest and
most authoritative business and investment information sources. Alongside
topical, daily news on worldwide
tax developments, you can receive weekly newswires or
access up-to-date intelligence
reports on a range of legal, tax and investment subjects.
FREE TRIAL NEWS SUBSCRIPTION
Our 16 constantly updated
intelligence reports cover every important aspect of 'offshore' and international
tax-planning in depth, including banking secrecy, the EU's savings tax
directive, offshore funds, e-commerce, offshore gaming and transfer pricing.
Reports are available for immediate downloading or as subscription
services with news pages.
|
|
 |
|
LAWANDTAX-NEWS.COM
