In this article in the Tax Journal, we comment on the recent FTT case, GCH Corporation, which highlighted the potential for tax avoidance by relying on the change in the tax treatment of LLPs from transparent to opaque upon the appointment of a liquidator. 

In order to close this loophole, the Government has announced legislation to introduce a deemed tax point at the time when assets are contributed to an LLP, in circumstances where the LLP is subsequently liquidated. As well as being indicative of a strong focus on preventing tax avoidance, the changes also reflect increasing scrutiny of the taxation of LLPs and their members.

Read the full article.