PARTNERSHIPS

Can it really be right that the taxability (or not) of a receipt can be determined by the partnership, with the recipient partner having no right to object? David Whiscombe (David Whiscombe LLP) discusses a tribunal decision that considered for the first time the scope of TMA 1970 s 12ABZB.

HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.

Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.

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). 

Matthew Shayle (Wiggin Osborne Fullerlove) highlights a UK tax trap for Guernsey law limited partnerships.

HMRC’s approach and recent tribunal decisions on mixed member partnership taxation have led to some uncertainty for individual and corporate partners. Liesl Fichardt and Emily Au (Quinn Emanuel Urquhart & Sullivan) assess the current state of play and what can be done to minimise risks.

Paul Beausang and Anisha Polson (Eversheds Sutherland) provide a refresher guide to what must be among the most complex of all the SDLT rules.

Andrew Howard (Ropes & Gray) examines the decision that covers some fundamental questions of UK partnership tax.

Natasha Kaye and Reshma David (Cooley) examine the scope of the close company indirect loan to participator rule in CTA 2010 s 459.