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Taxation of Partnerships and Private Capital Structures

Taxation of Partnerships and Private Capital Structures
2nd Edition
Series:  Sweet & Maxwell's Tax Library
Practice Area:  Partnerships, Taxation Law
ISBN:  9780414114951
Published by:  Sweet & Maxwell
Publication Date:  23 Sep 2024
Subscription Information:  Non-Subscribable Product
Format:  Hardback
PRODUCT INCLUDES:
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PRODUCT DESCRIPTION

Taxation of Partnerships and Private Capital Structures addresses in detail the technical and practical UK tax issues that arise in relation to trading and professional partnerships and LLPs and in relation to investment fund partnerships and related structures. As well as discussing the UK tax landscape for all types of partnerships and private capital structures, the book contains an extensive discussion of the special regimes (including those for disguised investment management fees, carried interest and income based carried interest) which supplement these rules for the investment 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 (and a significant amount of related case law) 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.

The second edition represents a significant rewrite and is updated to reflect the myriad of new case law and legislation since 2021 as well as the experience of the authors and the changing positions of HMRC since then.

The new edition also includes 3 new chapters covering:

  • The offshore fund rules
  • Pillar 2
  • The UK Qualifying Asset Holding Company (QAHC) regime

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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. Cessation / retirement / expulsion / annuities
  15. Merger of partnerships
  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
  28. The offshore funds rules
  29. QAHC
  30. Pillar 2
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