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The Readers' Forum query Umbrella LLPs concerned a scenario where one limited liability partnership (LLP A) which owned property wanted to arrange for the purchase of other properties but also wanted these to be owned by separate limited liability partnerships LLP B LLP C etc. in which it and a company would be the members.
The question in Umbrella LLPs was whether the members of LLP A had to show the property income of LLP A LLP B and LLP C on their own tax returns or whether the whole of LLP A's share should be shown on its return with the members only showing their membership of LLP A on their own returns.
The reply from Brumus argued that only one return would be required based on the wording of ITTOIA 2005 s 264 and s 859(2). However HMRC now...
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