Hear unique insights and guidance direct from:
• HM Revenue & Customs on schemes and investors
• 6 Collective Investment Scheme Managers
• The Investment Management Association (IMA)

Get to grips with challenges of:
• Implementing the Offshore Funds Rules
• Tax Elected Fund Regime practicalities
• UCITS IV and the tax implications
• Recent Hedge Fund Industry developments

Clarify the latest tax position associated with:
• Foreign Profits and access to Tax Treaties
• Trading vs. Investment distinction
• VAT Legislation, Litigation and Exemption
• Property Fund Sector and Vehicles

8.45 Registration

9.00 Chairman’s Opening Remarks

Alistair Nash
Group Tax Manager
Investment Operations
LLOYDS BANKING GROUP

9.15 A Business Overview of Key Developments Impacting the Collective Investment Scheme Sector

• UCITS4:
- Can the UK realistically be a fund domicile for masters and feeders
- What will happen to the management companies
• Global tax crackdown - what is the future for ‘offshore’ fund domiciles
• The Alternative Investment Fund Managers Directive:
- What's all the fuss about
- What will it mean for funds generally and for property and hedge funds in particular
• The ASB's proposals for full IFRS convergence - why they matter
• The Retail Distribution Review and Adviser charges - new tax costs for fund investors

Julie Patterson
Director – Authorised Funds & Tax
INVESTMENT MANAGEMENT ASSOCIATION

9.50 An HRMC Overview of Developments in the Taxation of Collective Investment Schemes and their Investors
• The new offshore funds regime
• Tax comparison of offshore and onshore funds - underlying principles
• FAIFs
• Recent changes to the taxation of authorised investment funds (onshore)
• Trading v Investment
• Investment Trust Companies
• Issues going forward

John Buckeridge
Policy & Technical Adviser, Collective Investment Schemes
HM REVENUE & CUSTOMS

Angela Nagarajah
Policy & Technical Adviser, Collective Investment Schemes
HM REVENUE & CUSTOMS

10.25 Taxation of Foreign Profits and the Implications for Access to Tax Treaties

• An outline of the new rules
• How they affect Authorised Investment Funds
• The impact of the rules on Investment Trusts
• Practical considerations associated with the new rules:
- impact on excess management expenses
- streaming implications
- treatment of derivative contracts
• Access to tax treaties and other withholding tax considerations

Dana Ward
Partner
GRANT THORNTON

11.00 Refreshment Break

11.15 Implementing the Offshore Fund Rules

• The revised definition - are your funds in or out
• Entering the new regime - what are your options
• Maximising tax efficiencies for investors - investor elections / deferral of entry into the regime
• Calculating reportable income
• Trading versus investment, genuine diversity of ownership and the equivalence condition
• Bond funds compared to equity funds
• Reporting requirements
• Breaches

Teresa Owusu-Adjei
Partner
PRICEWATERHOUSECOOPERS

Suzanne Ashwell
Senior Manager
PRICEWATERHOUSECOOPERS

11.50 Panel Session: Practical Perspectives from the Coal Face

Nigel Fleming
Director – International Tax
BLACKROCK INVESTMENT MANAGEMENT

Charlotte Worthington
Group Tax Manager
JUPITER ASSET MANAGEMENT

Ed Venner
Director – International CFO
LEGG MASON

Malcolm Richardson
Head of Tax
M&G

Kevin Charlton
Head of Operational Taxes -EMEA
UBS GLOBAL ASSET MANAGEMENT

12.30 Lunch Break

1.20 Addressing the Practicalities of the Tax Elected Fund Regime

• An overview of the rules
• What funds are likely to benefit from making an election
• What investors are likely to benefit from investing in TEFs
• Potential impact on a fund’s access to double tax treaties
• Some of the practical issues that will arise from the regime

Stuart Chalcraft
Director
ERNST & YOUNG

1.55 Clarifying the Current Position on Trading vs. Investment

• A look at developments in HMRC’s interpretation
• The white-list rules for UK authorised funds and ‘equivalent’ offshore funds
• Current status for non-equivalent offshore funds
• Relevance to the investment manager exemption
• UK vs. US interpretation and implications

Jorge Morley-Smith
Senior Manager
DELOITTE

2.30 Examining Recent Capital Movements in the Property Fund Sector and the Competitiveness of the Vehicles Available

• What the key tax drivers likely to determine the form of the Property Fund
• What are the main vehicles used in the market place
• Which vehicles have dominated recent market launches and why
• The role of Property Authorised Investment Funds alongside REITs
• Some practical considerations of a property fund (e.g. trading v investment, Sch 13)

Caroline Fleet
Associate Partner
KPMG

3.05 Refreshment Break

3.25 Assessing Recent UK and International Developments Impacting the Hedge Fund Industry

• The impact of the Directive on the location of managers and hedge funds
• How the recent UK income tax changes have influenced domicile for managers and the structuring of their funds
• The tax impact on managers of moving into ‘traditional’
• Influences on fund domicile and the case for UK onshoring

Rachel Hanger
Partner
KPMG

3.50 Clarifying VAT Developments for the Asset Management Industry

• Offshore funds exemption - October 2008 changes
- The Scottish Equitable period – alternatives
- Compound interest
• Pension funds and VAT exemption
• Future of the fund management exemption (EU Review of VAT Treatment of Financial Services)
- UCITS IV, AIFM Directive

Peter Dylewski
Senior Manager
ERNST & YOUNG

4.25 Highlighting the Tax Issues Arising from UCITS IV

• The tax residency of the management companies and their funds
• Transfer pricing issues
• The taxation of cross border flows
• Tax consequences for the investor

Eliza Dungworth
Tax Partner
DELOITTE

5.00 Chairman’s Summation and Close of Conference

John Buckeridge, Policy & Technical Adviser, CIS, HM Revenue & Customs
Angela Nagarajah, Policy & Technical Adviser, CIS, HM Revenue & Customs
Alistair Nash, Group Tax Manager, Investment Operations, Lloyds Banking Group
Nigel Fleming, Director – International Tax, Blackrock Investment Management
Charlotte Worthington, Group Tax Manager, Jupiter Asset Management
Ed Venner, Director – International CFO, Legg Mason
Malcolm Richardson, Head of Tax, M&G
Kevin Charlton, Head of Operational Taxes –EMEA, UBS Global Asset Management
Julie Patterson, Director – Authorised Funds & Tax, Investment Management Association
Teresa Owusu-Adjei, Partner, PricewaterhouseCoopers
Eliza Dungworth, Tax Partner, Deloitte
Rachel Hanger, Partner, KPMG
Dana Ward, Partner, Grant Thornton
Stuart Chalcraft, Director, Ernst & Young
Caroline Fleet, Associate Partner, KPMG
Suzanne Ashwell, Senior Manager, PricewaterhouseCoopers
Jorge Morley-Smith, Senior Manager, Deloitte
Peter Dylewski, Senior Manager, Ernst & Young