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New mixed partnership after 5/12/13

Would an OMB corporate member end up paying tax as employee?
I have a client wanting to use this vehicle, where two existing companies would come together in partnership, to be joined at a later date by one more. I cannot find chapter and verse, but from what I have read and heard, it seems to me that the individuals would be taxed as individuals? Is this correct, and how would this work? I've read "Partnerships: A review of two aspects of the tax rules" guidance, but it is not clear to me


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Is there any reason that they can't (or won't) set up a third company owned equally by the 2 existing companies?

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