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QuestionMy client runs a business through a limited liability partnership. It was established in this form for legacy reasons many years ago. The business proved successful, and the individual founders took on investment from two companies who now...
Dulcie Daly (Goodwin) considers the complexities that can arise for taxpayers when share sale proceeds include deferred amounts.

Paul Townson and James Flint (BDO) consider whether a sale to an EOT is still the best route for a potential future sale of a privately owned trading business.
Sarah Richards (Sedulo Tax Advisory) explains why establishing a UAE image rights structure does not in itself remove UK tax exposure.

Henry Lowe (Mercer & Hole) explores how best to fund a divorce payment now that the non-dom regime has been abolished.

Sarah Ling and Ellen Wildig (Macfarlanes) explore the wider impact for family-controlled businesses of the upcoming reforms to business property relief.

Alyssa Haggarty and Claire Weeks (Maurice Turnor Gardner) consider the status of the so-called ‘revenue rule’ and the options available to HMRC to seek assistance in the collection of tax abroad.
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Jane Johnson (Birketts) advises on the IHT consequences of a US trust for US citizens moving to the UK.
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