Salaried members rules: the position for LLPs after BlueCrest
Emily Clark (Head of Asset Management) and Ian Zeider (Knowledge Counsel) have recently co-authored a Tax Journal article on the Upper Tribunal's decision in HMRC v BlueCrest Capital Management (UK) LLP relating to the application of the salaried members rules. In its decision, the Tribunal rejected HMRC’s restrictive interpretation of the exclusions from salaried member status.