Partnership Tax and Tax Planning Experience

Partnership structures

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.

Co-ownership structure

Acting for the Crown Estate in connection with a shopping centre in Leeds held jointly through a partnership structure.

Cardiff Bay

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).