Quinn Emanuel Partner Liesl Fichardt, and Associate Emily Au, both based in our London office, have once again been published by the Tax Journal. Their article titled 'What is a 'capital' stake in an LLP?' discusses the nature of a capital stake and the tax treatment of any receipts upon disposal, which is being revisited in the context of LLPs. Recent case law has highlighted the significance of these principles, which involve corporate and tax issues, with HMRC questioning the validity of "capital" interests.
Read here (non-subscribers may access the article free of charge by registering with the Tax Journal website).