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Taxation of Partnerships and Private Capital Structures, 2nd Edition

Taxation of Partnerships and Private Capital Structures, 2nd Edition

Author: Damien Crossley; Mark Baldwin
Publisher: Sweet & Maxwell U.K.
ISBN: 9780414114951

Previous Edition ISBN: 9780414074637
Published In: October 2024
Format: Hardback
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: HKD 3,264.00

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Description
Contents

Details

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

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. Retirement and expulsion
15. Partnership mergers
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