Euro firm weighs in on Internal Revenue ruling

By Allison Bell

July 12, 2009 at 08:00 PM

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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.

The recent IRS tax revenue rulings have provided more clarity for the life settlement investment community, the firm says.

The rulings "have also highlighted the need for transparent investment vehicles," Jose Garcia, chief executive officer of Carlisle, says in a statement.

Because of the way the Peninsula Life fund is structured, the investors should be no worse off as a result of pooling their investments than if they had invested directly in the relevant investments held by the FCP on their behalf, Carlisle says.

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