Extract to table

The purpose of this memorandum is to provide a comprehensive assessment of the Cayman Islands tax and regulatory framework applicable to each step of the Reorganization and to identify the regulatory action items and compliance obligations that must be addressed to effectuate the transaction within the target timeline

Additionally, the economic substance requirements under the International Tax Co-operation (Economic Substance) Act (as revised) (the "ES Act") must be evaluated for the new feeder entities to confirm that they are not themselves conducting "fund management" as a relevant activity in the Cayman Islands

The FATCA and CRS reporting obligations applicable to the legacy vehicles must be transitioned to the new feeders, and AML/CTF and data protection compliance must be maintained throughout the process

Under this legislation, exempted limited partnerships and exempted companies may obtain undertakings from the Cayman Islands government that no law subsequently enacted imposing any tax to be levied on profits, income, gains, or appreciation shall apply to them, for a period of up to fifty (50) years from the date of the undertaking

In particular, the Luxembourg tax regime includes anti-avoidance provisions that must be evaluated in connection with the dissolution of the Luxembourg vehicles, and the U

Exempted limited partnerships that meet this definition must register with CIMA