Salaried Members Rules - Limited liability partnerships or "LLPs" are common corporate vehicles utilised by the financial services sector to establish UK investment management operations and other financial businesses and,...more
BlueCrest Capital Management (UK) LLP v HMRC [2022] UKFTT 204 (TC) is the first case considering the UK salaried members rules under ss 863A – 836G Income Tax (Trading and Other Income) Act 2005 (the “Salaried Members...more
The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
The new regulations will have a direct impact on the formation of partnerships in the international context. For most of the past decade, contributions to partnerships (including LLCs taxed as partnerships) have been...more
Under the Section 752 regulations, partnership liabilities (including liabilities of LLCs that are taxed as partnerships) are allocated among the partners based on who bears the economic risk of loss. If no partner is...more