Jitendra Patel (BDO) examines the rules six years since their introduction and in light of the first reported case on their application.
The mixed membership partnership rules that were introduced in 2014 brought about a significant change in partnership taxation.
Leading up to the change in law it had become relatively common to see partnerships (including LLPs) with mixed membership structures operating within the professional services and investment management sectors. Alongside individual members who worked in the business such partnerships also had one or more corporate members often owned by some or all of the individual members or having some other connection with them.
The reasons for the mixed membership structure are often specific to each client but common themes included:
facilitating the transfer of a business from a company to a partnership;
enabling the retention of working or regulatory capital...
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Jitendra Patel (BDO) examines the rules six years since their introduction and in light of the first reported case on their application.
The mixed membership partnership rules that were introduced in 2014 brought about a significant change in partnership taxation.
Leading up to the change in law it had become relatively common to see partnerships (including LLPs) with mixed membership structures operating within the professional services and investment management sectors. Alongside individual members who worked in the business such partnerships also had one or more corporate members often owned by some or all of the individual members or having some other connection with them.
The reasons for the mixed membership structure are often specific to each client but common themes included:
facilitating the transfer of a business from a company to a partnership;
enabling the retention of working or regulatory capital...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
