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Jenny Wheater


Jenny Wheater is a corporate tax specialist. She advises clients on the tax aspects of establishing and operating various types of investment funds, including private equity, debt and real estate funds. In this regard Jenny has extensive experience in the area of fund tax terms and, in relation to fund managers, carried interest and co-investment arrangements and the complex anti-avoidance provisions arising from these. On an international level, Jenny is highly knowledgeable about the Base Erosion and Profit Shifting project undertaken by the OECD and how that may impact fund investment structures, most notably in regarding treaty abuse and hybrid instruments.  On the domestic front, Jenny has recent expertise on the recent changes to the taxation of non-residents on gains relating to UK real estate.

Jenny sits on the British Venture Capital Association (“BVCA”) Tax Committee and on the Association of Real Estate Funds (“AREF”) Brexit Committee. In these capacities she has negotiated at the highest level on behalf of the investment fund industry and has a practical sense of government priorities. Jenny is the lead editor of the book Global Tax Aspects of Private Fund Formation published in 2016 and is the editor of the IBA publication Business Law International. Although originally UK qualified, Jenny has an LLM in US Taxation from Georgetown University Law Center in Washington DC and is admitted to practice in both England and Wales and New York.

Agenda Sessions

  • Considering Examples of How the EU Mandatory Disclosure (DAC6) Rules are Likely to Impact in Practice