By Steven Whittaker and Nicholas Fagge, Schulte Roth & Zabel LLP Background In May 2013, HM Revenue and Customs (“HMRC”) consulted on proposals in two areas to tackle perceived tax avoidance via partnerships. The first area was disguised employment in Limited Liability Partnerships (“LLPs”) and the second was the tax-motivated allocation of business profits […] Read more »
Hedge Fund LLPs and Other Partnerships in Choppy Waters for Tax?
From Daniel Lewin of Kaye Scholer On May 20, 2013, HM Revenue & Customs (HMRC), the UK Revenue authority, published a consultation document that proposes significant new anti-avoidance tax measures aimed at UK partnerships, and in particular at English limited liability partnerships (LLPs). This consultation document continues to be the subject of controversial discussion between […] Read more »
Return of Your Capital over Return on Your Capital
By Lee Robinson, Altana Wealth Limited It is difficult to know where to start. 2013 is beginning to look like a pivotal year for so many regions globally. The bear is savaging each market in turn. First it was commodities then emerging market currencies followed by everything else in emerging markets. China is back to […] Read more »
UK Tax Plans Snare Big US Hedge Funds – Graphic of the Day
Last week the “Financial Times ” ran a story that the UK tax authorities (HM Revenue & Customs) were looking to tackle the disguising of employment relationships through limited liability partnership structures and the manipulation of profit and loss allocations to achieve tax advantages. The Table Below Shows 15 of the largest 25 hedge fund […] Read more »