PARTNERSHIPS

HMRC clarifies its position.

Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published, writes Mark Saunders (PwC).

Jonathan Cooklin

Dominic Foulkes

Dominic Foulkes and Jonathan Cooklin (Davis Polk) share their approach to understanding some of the tax issues.

The government is consulting on proposals for a series of reforms to limit the risk of misuse of limited partnerships.

James McCredie

The long awaited legislation on changes to partnership taxation has been published – and it is not as bad as you might have feared, writes James McCredie (Macfarlanes).

James McCredie

HMRC’s new consultation highlights a number of administrative changes which could make life easier for HMRC and taxpayers. However, a couple of the proposals to change substantive tax charges may have unwanted side effects, writes James McCredie (Macfarlanes).

Cathya Djanogly

Partner’s return inconsistent with partnerships’ return

Laura Charkin

Stephen Pevsner

Laura Charkin and Stephen Pevsner (King & Wood Mallesons) look back on a turbulent year for fund managers and consider the proposed new ‘income-based carried interest’ tax rules.

Santhie Goundar

The Cultural Test (Television Programmes) (Amendment) (No.

Julian Hickey

Michael Conlon KC

‘They also pay who only sit and wait…’ Michael Conlon QC and Julian Hickey (Temple Tax Chambers) examine the High Court decision in Rowe on the legality of partner payment notices.

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