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Salaried LLP members: where are we now?
Jitendra Patel
LLPs would be well advised to consider the status of their members in light of recent developments, writes Jitendra Patel (BDO).
The Boston Consulting Group UK LLP and others v HMRC
Disposals of LLP interests were taxable as miscellaneous income.
Salaried members rules: the position for LLPs after BlueCrest
Emily Clark
Ian Zeider
Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in
BlueCrest
, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?
Tax and the City review for April 2023
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s
round-up that includes Spring Finance Bill measures affecting financial
services.
Significantly influential: the BlueCrest salaried members appeal
Amanda Hardy KC
Oliver Marre
The result of the
BlueCrest
appeal represents a good outcome for many businesses structured as LLPs, write Amanda Hardy QC and Oliver Marre (5 Stone Buildings).
Ingenious Film Partners in the Court of Appeal: lights, camera, action!
Heather Self
Hannah Hurley
Heather Self and Hannah Hurley (Blick Rothenberg) examine the key points and the broader implications of the recent Court of Appeal decision.
Odey and Hffx: partnerships with mixed membership
Helen Coward
,
Guy Bud
,
Hugh Gunson
Helen Coward, Guy Bud and Hugh Gunson (Charles Russell Speechlys) examine two decisions that raise interesting points of law relating to remuneration arrangements in partnerships with individual and corporate membership.
Taxing excess Covid-19 support payments
Helen Adams
Richard Morley
Helen Adams and Richard Morley (BDO) explore how HMRC is able to recover excessive Covid-19 support payments.
Tyrwhitt: when employees become partners
Dominic Stuttaford
Sofia Casselbrant
Dominic Stuttaford and Sofia Casselbrant-Multala (Norton Rose Fulbright)
review the NICs treatment of bonus payments by LLP to former employees
who subsequently become members.
Inverclyde: a retrospective line in the sand
Sarah Stenton
,
Lisa Vanderheide
,
Lee Ellis
The introduction of retrospective legislation to fix enquiry framework issues for LLPs shows how far HMRC is prepared to go to protect its position.
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2
EDITOR'S PICK
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
1 /7
SDLT: gardens, grounds and grazing
Max Schofield
2 /7
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
3 /7
A capital blow for deducting management expenses
Kyle O'Sullivan
4 /7
VAT on private school fees: 10 takeaways
Etienne Wong
5 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
6 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
7 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
A capital blow for deducting management expenses
Kyle O'Sullivan
VAT on private school fees: 10 takeaways
Etienne Wong
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
NEWS
Read all
HMRC manual changes: 13 September 2024
Budget Responsibility Bill enacted
ECJ overturns General Court's judgment in Apple State Aid case
Chancellor confirms business tax roadmap will be in Budget
Sunset date for EIS and VCT relief
CASES
Read all
Barclays Service Corporation and another v HMRC
Janet Bray Ltd v HMRC
Equity Advisory Ltd and another v HMRC
Other cases that caught our eye: 13 September 2024
HMRC v S&L Barnes Ltd
IN BRIEF
Read all
Self’s assessment: Business Tax Roadmap
Recognising ‘imported losses’ under the loan relationship rules
Suspended penalties
R&D claim notification
The everyday economy
MOST READ
Read all
HMRC manual changes: 13 September 2024
Budget Responsibility Bill enacted
Self’s assessment: Business Tax Roadmap
Recognising ‘imported losses’ under the loan relationship rules
Suspended penalties