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Taxation of Investment and Trading Partnerships and LLPs

Taxation of Investment and Trading Partnerships and LLPs
Series:  Sweet & Maxwell's Tax Library
Practice Area:  Partnerships, Taxation Law
ISBN:  9780414074637
Published by:  Sweet & Maxwell
Publication Date:  31 Oct 2021
Subscription Information:  Non-Subscribable Product
Format:  Hardback
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PRODUCT DESCRIPTION

Taxation of Partnerships and LLPs addresses in detail the technical and practical UK tax issues that arise in relating to trading and professional partnerships and LLPs and investment fund partnerships. As well as discussing the UK tax landscape for all types of partnerships and LLPs, the book contains an extensive discussion of the special regimes (including those for disguised investment management fees, carried interest and income based carried interest) introduced in recent years which supplement these rules for the asset management community.

The UK treatment of partnerships is still largely non-statutory while the tax treatment of flows to investment managers has been subject to extensive changes since 2014. The book helps demystify these complex areas of tax by offering an explanation of the technical issues, reasoned views on the practical application of these rules, and the positioning of HMRC.
  • Focus on investment and trading partnerships
  • In-depth coverage of the recent changes focused on asset managers trading as LLPs
  • Openly discusses areas where the view of HMRC and tax community diverge and give an opinion on where the right answer lies

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CONTENTS

  • 1. Partnerships, partners and LLPs: An introduction
  • 2. Framework for calculating and allocating partnership income
  • 3. Which vehicle to choose - partnership, LLP or company?
  • 4. Chargeable gains
  • 5. Tax compliance and management
  • 6. An international perspective
  • 7. UK taxation of partnerships with an offshore element
  • 8. LLP members as employees, salaried members and IR35
  • 9. The employment related securities rules and partnerships
  • 10. Acquisitions of securities in self-employed context
  • 11. Anti-avoidance rules
  • 12. Losses
  • 13. Financing partnerships
  • 14. Retirement and expulsion
  • 15. Partnership mergers
  • 16. Mixed member rules
  • 17. Loan relationships
  • 18. Intangible fixed assets
  • 19. Effect of partnerships on corporate groupings and tax reliefs
  • 20. Background to investment management taxation
  • 21. DIMF rules
  • 22. IBCI rules
  • 23. Carried interest rules
  • 24. DIMF/Carried interest - particular topics
  • 25. Transfer taxes
  • 26. IHT
  • 27. VAT

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