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Offshore rollup funds

06 June 2007
Issue: 4111 / Categories: Forum & Feedback

If an initial investment is made into a fund that does not have distributor status and subsequently further funds are added so new shares in the fund are bought, how do the identification rules work when moneys are withdrawn?

If an initial investment is made into a fund that does not have distributor status and subsequently further funds are added so new shares in the fund are bought how do the identification rules work when moneys are withdrawn? Although the profit is treated under income tax rules does the identification of the underlying shares sold follow the normal capital gains tax rules — ie if bought before taper relief was introduced are the shares pooled and if after are they dealt with as separate holdings identified on a last in first out basis with the profit accruing apportioned across the 'pool' and the separate holdings?
Secondly if an investment in shares in a rollup fund is transferred between spouses is this deemed a disposal at market value hence triggering the taxation of the income rolled up and a rebasing of...

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