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HMRC Appeals Tax Planning

Skadden, Arps, Slate, Meagher & Flom LLP

Members of UK LLPs and Significant Influence: Commentary on HMRC v. BlueCrest Capital Management (UK) LLP

On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more

Dechert LLP

Bluecrest - Court of Appeal Narrows “Significant Influence” Test for LLP Salaried Member Rules

Dechert LLP on

The Court of Appeal has taken an unexpectedly narrow and unfavourable interpretation of the significant influence test (Condition B) of the LLP salaried member rules in HMRC v Bluecrest Capital Management (UK) LLP. The...more

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