Limited Liability Partnership

See : http://p2pfoundation.net/Limited_Liability_Partnership

Differences Between Countries or States

Ireland ( not UK ) Vs England

Question from User:Dante to Chris Cook :

A small question regarding Limited Liability Partnerships, and potential differences in legislation depending on countries where they are set up.

I shared with Mick one of your presentations. Mick noted that in Ireland ( not UK ) it is not fully a Limited Liability, as there needs to be at least one of the partners who takes full liability, the so called "General Partner". I do not sense this may be the case in UK LLP's, but then, as apparently Ireland does copy quite a bit on the UK, there is some doubt about it.

It seems clear that there are differences in LLP definitions accross countries or even States within a country.

http://www.companylawclub.co.uk/topics/limited_liability_partnerships_llps.shtml#Ltd

VS

http://www.companyformations.ie/company-formations/company-types/#section5

"An LLP must consist of at least one general partner and one limited partner. The partnership should not consist of more than 20 persons or, if carrying on the business of banking, of more than 10 persons. The general partner(s) is/are liable for all the debts and obligations of the firm. The limited partners contribute a stated amount of capital and are not liable for the debts of the partnership beyond the amount contributed. A partnership can be made up of natural persons or corporate entities. Investment Limited Partnerships (ILP’s) are used sometimes by the funds industry." Company Law: www.companylawclub.co.uk

Reply by Chris Cook

Hi. The Irish entity is similar to the US 'Limited Partnership' which is also similar to the post 1907 UK Limited Partnership Chris Cook The UK LLP does not distinguish between investors (limited partners) and managers (general partners) in the same way Chris Cook Th UK LLP is not dissimilar to the US LLC Chris Cook the difference is that the US LLC has two (optional) tax treatments Chris Cook and also must have a defined term (as must a lease) Chris Cook whereas the Uk LLP is of indefinite term Chris Cook That means that the UK LLP is technically a corporate body Chris Cook whereas the LLC is a legal person Chris Cook but NOT a corporate body Chris Cook which requires permanence Chris Cook The LLP agreement is infinitely flexible Chris Cook with a few default provisions