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