Partnerships

Each stage of a business partnership - formation, operation or eventual termination - will have tax consequences. We draft partnership agreements for limited liability companies, general and limited partnerships, and limited liability partnerships, assessing the tax issues for each.

We help clients to achieve the best tax efficiencies in various circumstances, including:

  • Choice of entity
  • Initial structuring
  • Day-to-day tax planning
  • Roll-ups
  • Mergers
  • Acquisitions
  • Sales of businesses and property
  • Reorganizations
  • Restructurings.

Recent work

  • Advising the partners of a large financial services business on the structure of their business, succession planning and conversion to limited liability partnership status. This involved a detailed review of the partnership and its assets, the personal tax profiles of each partner, the risks inherent in the business and its future aims.
  • We advised a limited liablity company that had recently refinanced its debt and distributed a substantial part of the borrowed proceeds to its investors with regard to the US income tax impact of the refinancing and distributon to the company and the individual investors.
  • We advised a family office regarding the use and structuring of a 'tracking' partnership, which enabled the pooling of the family's investments in a single entity structure while allowing each member of the family the freedom to allocate and tax efficiently reallocate their partnership investment to assets best suited to their own financial needs, objectives, tax status and risk/return profile.

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