The following Private Client Q&A provides comprehensive and up to date legal information covering:
In this Q&A we have assumed the following:
the partnership in question is a Scottish limited partnership
HMRC accepts that the US Limited Liability Companies (LLCs) which own the Scottish limited partnership (SLP) are opaque for UK tax purposes
the SLP is going to register under The Scottish Partnerships (Register of People with Significant Control) Regulations 2017, SI 2017/694
the trust in question is not UK resident for UK tax purposes
The key issue is whether, in any particular tax year, the trust is a ‘taxable relevant trust’. A taxable relevant trust
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