This episode of Tax Snax discusses the following recent private client tax cases:
- HMRC v Bluecrest Capital Management (UK) Limited [2025] EWCA Civ 23 – Ben Symons and Shanzé Shah discuss the Court of Appeal’s recent decision concerning the salaried members’ rules in relation to Bluecrest’s LLP. At issue was whether Bluecrest’s LLP was liable for a further £55 million in National Insurance Contributions because its members were effectively fell within the salaried members’ rules;
- Louwman v HMRC [2025] UKFTT 295 (TC) – Ben Symons and Shanzé Shah discuss the First-tier tribunal’s decision in relation to whether “offshore income gains” and “accrued income profits” are “protected foreign source income” under the protected trust regime and therefore whether these items of income were attributable to the settlor when they arose in the trust.
