diggerdigger
Registered User
- Messages
- 20
I'm Irish resident and domiciled. I have some investments in offshore funds, based in Delaware. The funds are structured as private closed investment partnerships,SEC regulated, holding profit participation notes, calling principal, and repaying principal and interest on underlying investments in a master fund.
I have been trying to determine the correct method of declaring. To date I have declared each principal call as an acquisition of a material interest. The principal returns distributions would not be not taxable (i think as effectively disposals with no gain), and then subsequent interest payments (pp interest on the note) would be taxable as fund distributions as income at 41%.
Any thoughts on the correctness of my approach.
I have been trying to determine the correct method of declaring. To date I have declared each principal call as an acquisition of a material interest. The principal returns distributions would not be not taxable (i think as effectively disposals with no gain), and then subsequent interest payments (pp interest on the note) would be taxable as fund distributions as income at 41%.
Any thoughts on the correctness of my approach.