Andrew Howard (Ropes & Gray) examines the decision that covers some fundamental questions of UK partnership tax.
The judgment of the First-tier Tribunal in BlueCrest Capital Management Cayman Ltd and others v HMRC [2020] UKFTT 298 (TC) is a difficult read. However it is worth persevering because at its heart lie some surprising and potentially far reaching conclusions on some fundamental questions on the UK taxation of partnerships.
BlueCrest is a hedge fund and the case involves how the profits earned by the fund manager should be taxed. The structure varied over time but essentially the fund manager (the ‘fund manager’) was a partnership (either a limited partnership or an LLP). The identity of the partners also varied primarily consisting of the senior individuals involved in managing the fund and at least one third party UK corporate with a stake in the business.
Sale of a 19% stake...
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Andrew Howard (Ropes & Gray) examines the decision that covers some fundamental questions of UK partnership tax.
The judgment of the First-tier Tribunal in BlueCrest Capital Management Cayman Ltd and others v HMRC [2020] UKFTT 298 (TC) is a difficult read. However it is worth persevering because at its heart lie some surprising and potentially far reaching conclusions on some fundamental questions on the UK taxation of partnerships.
BlueCrest is a hedge fund and the case involves how the profits earned by the fund manager should be taxed. The structure varied over time but essentially the fund manager (the ‘fund manager’) was a partnership (either a limited partnership or an LLP). The identity of the partners also varied primarily consisting of the senior individuals involved in managing the fund and at least one third party UK corporate with a stake in the business.
Sale of a 19% stake...
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