Partnership Tax and Tax Planning Experience
Setting up a number of partnership structures for clients of Charterhouse (Accountants) LLP to enable tax-efficient profit-extraction. This has included setting up hybrid partnership between individuals and companies, advice on TUPE and restrictive undertakings, property and other transfer work.
Family limited partnerships
Setting up a number of family limited partnerships.
Corporate member planning
Advising the investment manager of an unregulated property fund on a tax-efficient LLP structure using corporate LLP members. We have advised other trading businesses on implementing similar tax planning.
Partnership tax dispute
Advising the nominated partner of a discontinued partnership in respect of a partnership tax dispute, which had been ongoing for a number of years before our involvement and which quickly reached a very satisfactory settlement.
Double partnership structure
Advising a firm of accountants about the tax implications of a complex double partnership structure, which was required to meet their client's commercial needs in relation to the holding of certain real estate interests.
Acting for the Crown Estate in connection with a shopping centre in Leeds held jointly through a partnership structure.
Advising an investment partnership on the use of a corporate structure to ensure the partners, which were UK pension funds, received investment income rather than trading profits (trading profits being outside the scope of pension funds' exemption from tax).