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Posted Wed, 26 Jul 2023 12:21:25 GMT by Sixto Olson
I would be grateful if you can clarify the tax treatment when an individual sells a mixed lot of an offshore investment fund including reporting and non-reporting units. Specifically the situation is the following: • On date 1 purchased some units of an offshore non-reporting fund at a price of 70 per unit • On date 2 purchased additional units of the same fund at a price of 80 per unit • On date 3 the fund converted from non-reporting to reporting. Unit price was at 75 • Units purchased on date 1 were standing at a gain, units purchased on date 2 were at a loss. No election was made on date 3 • Excess reportable income has been reported for all units since the fund converted to reporting • On date 4 all units are sold at a gain Can one split the units in the calculations and treat separately as a two different lots of non-reporting and reporting fund? Thanks
Posted Thu, 03 Aug 2023 07:18:40 GMT by HMRC Admin 20
Hi Sixto Olson,

Please have a look at IFM13510, as this guidance refers to a reporting fund that has not had reporting fund status at a time you held an interest.
Disposals should be reported under a single gain.  IFM13510 - Offshore Funds: investors in non-reporting funds: computation of offshore income gain: introduction

Thank you.

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