Partnerships and capital gains tax structures

Partnerships and capital gains tax structures

Author
Discussion

brickwall

Original Poster:

5,251 posts

211 months

Monday 31st August 2015
quotequote all
So Trump has had a go at hedge fund tax structures. I think he's an odious individual, but probably mostly agree with him on this one. I thought this was a loophole HMRC had closed a while back, when the the PE guys took a kicking in the UK.

But I recently heard a rumour I heard that the partners in a Magic Circle law firm are have structured it such that they pay CGT on their yearly earnings (at 28%), and not income tax (which would be at 45%). This seems even further from legit CGT than the PE/Hedge fund carried interest structures.
a) Anyone know if this is true?
b) If they're managing to make it work, I can't think the partners of other professional services firms aren't doing similar
c) How does this work legally? And how is HMRC unable to close this particular loophole?

brickwall

Original Poster:

5,251 posts

211 months

Monday 31st August 2015
quotequote all
Agree, but this one seems to be incredibly blatant. I'm sure you're not suggesting that the discrepancies make the behaviour OK.

(Though my personal favourite dodge has to be the classification of pupillages as 'scholarships', making them tax free. Some of these pupillages pay £60k for the year...)

brickwall

Original Poster:

5,251 posts

211 months

Saturday 5th September 2015
quotequote all
Thanks everyone. The informed PH wisdom seems to confirm my suspicions that the rumour probably isn't true.