Talking Tax: When is a partner not a partner?
Tax rules change quickly, and understanding what they mean in practice can be challenging. That’s why we’re launching Talking Tax, a new podcast series from Forsters, hosted by Tax partners Heather Corben and Elizabeth Small.
In each episode, Heather and Elizabeth explore the latest tax developments affecting businesses, investors and professional services firms, providing practical insight into what they mean, and the steps organisations should consider taking.
In our first episode, they discuss the Supreme Court’s landmark BlueCrest decision and its implications for LLPs and partner tax status.
The judgment has brought renewed focus to the question of when an individual can genuinely be treated as a partner for tax purposes. As Heather and Elizabeth explain, the Supreme Court’s message is clear: it is not sufficient to be a rainmaker or a high-performing portfolio manager. Instead, firms must consider whether individuals have legally enforceable rights and duties that give them significant influence over the affairs of the LLP.
The discussion covers:
- The key findings from the BlueCrest judgment.
- What “significant influence” means in practice.
- The risks for LLPs and professional services firms.
- How HMRC may respond.
- Practical steps firms should be considering now.
Whether you’re a business owner, investor or professional services leader, this episode provides valuable insight into one of the most significant partnership tax developments in recent years.
