U.K. Long‑Term Asset Fund: Key Vehicle Features and Notable Tax‑Planning Considerations (Part Two of Two)

The suite of fund vehicle options in the U.K. recently expanded when the U.K. Financial Conduct Authority officially enacted rules for long-term asset funds (LTAFs), which are a new category of authorized, open-end investment funds. With liquidity features similar to hybrid funds and a design specifically meant to appeal to pension plans and insurance funds, the hope is that the LTAF will help propel the U.K. forward as the preeminent U.K. private funds jurisdiction. In a two-part guest series, Cadwalader partners Michael Newell and Adam Blakemore introduce relevant information that fund managers need to know before adopting the LTAF. This second article considers some key features of LTAFs (e.g., liquidity, fees, marketing, etc.), as well as the vehicle’s tax treatment. The first article furnished an overview of LTAFs, where the vehicle fits among the other types of U.K. fund offerings, how it can be formed and the main actors involved in operating an LTAF. See “Employment‑Related Tax Issues and Significant U.K. Tax Developments for PE Sponsors to Monitor (Part Two of Two)” (Feb. 1, 2022); and “New U.K. LTAF, Updated E.U. Marketing Regulations and Trends in the Middle East Private Funds Industry (Part Two of Two)” (Jan. 18, 2022).

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