Carlisle Management Company S.C.A. says its life settlement fund should be well-positioned to respond to the recent Internal Revenue Service life settlement tax rulings.
The IRS clarified the tax status of life settlements and settlement investments in May 2009.
Carlisle, Luxembourg, the manager of The Peninsula Life Settlement Fund FCP SIF, reports that an FCP fund is “considered as being a tax transparent entity in Luxembourg.”
“A tax transparent entity is an entity which is not taxed either in representative capacity or in its own capacity as a tax-paying entity, but the tax is levied on the investors, in their domicile, on their share of income in the entity,” the firm says.