SPLLCSpecialty Publications LLC
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It came to the conclusion that although the assets belonged to SPLLC until they were distributed to its members, this did not mean that the profits and losses did not belong to the SPLLC members until the cash/property was distributed.
tax based on his share of profits from SPLLC as they arose to Swift or liable for tax on the equivalent of a dividend.
SPLLC stands somewhere between a Scots partnership and a UK company, having the partnership characteristics of the members being entitled to profits as they arise and owning an interest comparable to that of a partnership interest, and the corporate characteristics of carrying on its own business without liability on the members and there being some separation between Managing Members and other members falling short of the distinction between members and directors.