BTW, you've gotta love those U.K. LLPs. Non-tax pass-thru for foreign earned income!
Is that only if the beneficiary is non-dom?
I believe so. In fact it may require the foreign partner to be resident in a nation playing counterparty to the u.k. in a tax treaty. I am so totally not qualified to give remotely sound u.k. tax advice. But everybody should at least be aware of this interesting feature, so I recklessly spam it about.