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Limited Liability Company (LLC) HMRC Appeals

Goodwin

UK Salaried Member Employment Tax Rules - Recent Developments

Goodwin on

This client alert discusses recent developments relevant to members of UK LLPs in respect of the UK’s salaried member employment tax rules. In particular, it focuses on recent developments in relation to Condition B (the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Members of UK LLPs and Significant Influence: Commentary on HMRC v. BlueCrest Capital Management (UK) LLP

On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more

Proskauer Rose LLP

UK Tax Round Up - December 2023

Proskauer Rose LLP on

Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more

Troutman Pepper Locke

UK Supreme Court Decision in Anson v. HMRC Reverses Established Tax Treatment of US LLCs

Troutman Pepper Locke on

In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more

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