Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Partnership partition

04 January 2011
Issue: 4286 / Categories: Forum & Feedback , Capital Gains , Inheritance Tax
A family own shares in a property development company and are also the partners in a property investment partnership

X Ltd is a residential property developer.

The shares in the unlisted company are owned by Mr A and his sons B C and D as to 30/30/30/10 respectively.

There is also a property investment partnership PP which holds and lets out commercial and residential property but does not develop property or trade in any way.

The partners are Mr A (12.5%) Mrs A (6%) B (30%) C (30%) and D (21.5%).

The partnership agreement states that on the death resignation or retirement of a partner he or she will only be entitled to the balance on their capital account; there is to be no revaluation of assets.

To meet differing aspirations the family businesses have been reorganised. B exchanged his interest in PP for 70% of shares in X Ltd. No cash was paid by either...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon