Serena Lee Quoted in Private Equity International on Spring Budget 2023 Carried Interest Rules Update

For its daily briefing “Side Letter” Private Equity International (PEI) quoted Akin tax partner Serena Lee following the announcement in the UK Spring Budget 2023 of an elective accruals basis of taxation for carried interest. The changes will allow UK resident investment managers who receive carried interest to pay their tax liabilities earlier to align with the timing of their tax position in other jurisdictions.

Lee commented, “Whether the new election will actually permit claiming an improved foreign tax credit position in the US remains to be seen, as the new rules will need to be scrutinised from a US tax perspective: it is possible that the voluntary nature of the UK tax accrual may call such a claim into question in the US.”

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