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My UK resident and domiciled client has an interest in a number of different Delaware trading limited liability companies (LLCs).
In each case the current interest (profit loss and capital) is less than 5%. The client is also employed here by the UK arm of the US parent and has been for well over a year.
I am trying to ascertain whether entrepreneurs’ relief (ER) may be available in respect of the capital gain arising should the client dispose of these interests.
I am struggling to get clarity on whether or not the client is regarded in the UK as having an interest in a partnership or a company (reference to the Swift case).
The employment has no direct relevance to the LLC interests beyond the fact that one led to the other.
On the face of it and as evidenced by the forms 1065 my...
