Camilla Spielman

Legal Director

Camilla has provided tax advice to the Financial Services Group since 1990. She has wide experience of advising on the taxation of all types of investment funds and in particular advises fund management groups on new product development.

Camilla's UK work includes the tax structuring for authorised unit trust and OEIC launches and reconstructions, for both securities and property funds. She also advises on unauthorised funds, including exempt unauthorised unit trusts. Offshore, she advises on the structuring and restructuring of traditional and alternative funds, both open and closed-ended.

Recently, Camilla has worked on the launch and seeding of the Royal London Asset Management UK property authorised contractual scheme with a PAIF feeder. She has acted as sole or lead tax adviser in relation to most existing authorised contractual schemes and PAIFs, as well as on the only PAIF merger to date.

Camilla has contributed chapters to Tolley's Taxation of Collective Investment, IBFD online publication on Investment Funds and Private Equity as well as articles to journals. She has been involved in many industry initiatives including the development of PAIFs and authorised contractual schemes. She is a member of The Investment Association and Association of Real Estate Funds' tax committees.

Contributed to

5

Taxation of authorised investment funds—corporate investors

Practice notes

This Practice Note explains the tax treatment of entities within the charge to UK corporation tax who invest in open-ended investment companies (OEICs) and authorised unit trusts (AUTs), together referred to for tax purposes as authorised investment funds (AIFs). It looks at the tax treatment of distributions and disposals of investments where AIFs are bond funds or equity funds. It looks at the corporate streaming rules, qualifying investments test, equalisation and anti-avoidance rules. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

Tax

Taxation of authorised investment funds—genuine diversity of ownership condition

Practice notes

This Practice Note describes the genuine diversity of ownership (GDO) condition which certain authorised investment funds (AIFs) which are qualified investor schemes (QIS) or long-term asset funds (LTAFs) must (unlike other regulatory forms of AIFs) satisfy in order to access beneficial tax treatment under the AIF tax regime. It also explains how satisfying the GDO condition enables AIFs to benefit from the ‘investment transactions list’ (sometimes referred to as the ‘white list’), and also allows for entry into the property AIF (PAIF) and tax elected fund (TEF) regimes. It also looks at the GDO advance clearance procedure. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

Tax

Taxation of authorised investment funds—individual investors

Practice notes

This Practice Note explains the tax treatment of UK resident individuals who invest in open-ended investment companies (OEICs) or authorised unit trusts (AUTs), together referred to for tax purposes as authorised investment funds (AIFs). It looks at the tax treatment of distributions where AIFs are bond funds or equity funds and the CGT rules applicable to disposals, equalisation and umbrella funds. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

Tax

Taxation of authorised investment funds—taxation of the fund

Practice notes

This Practice Note looks at the taxation of authorised unit trusts (AUTs) and open-ended investment companies (OEICs), which are collectively referred to as authorised investment funds (AIFs) for tax purposes and are subject to a specific taxing regime. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

Tax

Taxation of authorised investment funds—what are they?

Practice notes

This Practice Note explains what authorised investment funds (AIFs) are for UK tax purposes. It looks at the regulatory framework applicable to AIFs, namely, the definition of a collective investment scheme (CIS) and the different regulatory forms that an AIF may take. It also explores the two legal forms of AIF, namely authorised unit trusts (AUTs) and open-ended investment companies (OEICs). This Practice Note also looks at AIFs which are umbrella funds. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

Tax