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SALARIED-MEMBERS


LLPs would be well advised to consider the status of their members in light of recent developments, writes Jitendra Patel (BDO).
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?

The BlueCrest salaried members case, three HMRC victories on SDLT and three recent taxpayer wins on penalties. Edward Reed and Thomas Schlee (Macfarlanes) review recent developments in the private client world.

Amanda Hardy KC and Oliver Marre (5 Stone Buildings) examine the first Upper Tribunal judgment on the meaning of ‘significant influence’.
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). 
Card image Stuart Pibworth Will Smith Leonard Ng Chris Brause
Will Smith, Leonard Ng, Chris Brause and Stuart Pibworth (Sidley Austin) review recent developments within the investment funds industry which faces numerous challenges in the form of UK and international tax initiatives, as well as ongoing regulatory change.
 

Jeanette Zaman and Zoe Andrews write that the recent changes to the partnerships tax rules highlight an increasing trend for loosely drafted, wide-reaching legislation that requires reliance on detailed guidance to identify its actual anti-avoidance targets

Helen Lethaby reviews recent developments affecting the City

HMRC has issued revised guidance notes for taxing LLP members. George Bull and Malcolm Cook consider whether the taxman listened to the profession’s concerns

Mark Baldwin considers the revised guidance on the new ‘salaried member’ rules, released last week by HMRC, that will treat members of an LLP as an employee for tax purposes in certain circumstances

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