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Partnerships with corporate members: how will new rules affect your clients?
KEY POINTS
- The profits of a corporate member of a partnership may be reallocated.
- Anti-forestalling rules apply to new arrangements from 5 December 2013.
- Consider removing the corporate member.
- Advantages of incorporation.
The proposals for mixed partnerships were examined in my article All mixed up. Among the important issues raised in response to consultation was the adverse effect on mixed partnerships established for mainly commercial reasons.
The draft law now included in Finance Bill 2014 Sch 13 Part 2 will become ITTOIA 2005 s 850C to s 850E ignores such comments apart from some points of detail.
Further change is unlikely so because the rules will operate for periods of account beginning on or after 6 April 2014 it is important now to take stock of them....
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