LLPS

Sarah Bond

Sarah Bond and David Haughey (Freshfields) discuss some of the practical challenges which arise in tax disputes involving partnerships and their members.

Constantine Christofi Craig Kirkham-Wilson Lauren Trask

Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.

Ashley Greenbank

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Henry Bennett-Gough

Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in Boston Consulting Group and its implications for mixed member LLP structures.

Claire Miles

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...

Farming LLP’s sideways loss relief fails commerciality test

Discretionary deferred profits via a corporate LLP were taxable as miscellaneous income

UT confirms broad meaning of ‘business’

Upper Tribunal rules on payments under LLP ‘capital interests’ and the mixed member partnership rules

Licence of client list was an intangible fixed asset for CT purposes

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