Tax Journal

Chris Sanger, Constantine Christofi, Craig Kirkham-Wilson

New HMRC measures risk cumulative constitutional and practical effects that piecemeal consultation may fail to reveal, write Chris Sanger, Constantine Christofi and Craig Kirkham-Wilson (EY).

Sara Sinfield

Beth Sercombe

Sara Sinfield and Beth Sercombe (Ashurst Perkins Coie) explore how AI can transform document review in tax investigations, highlighting the efficiency gains, practical limitations and importance of expert supervision.

Liz Fothergill

The reclassification of OIGs may appear to be a narrow technical adjustment solely related to the operation of the temporary repatriation facility, but it has wider practical implications, as Liz Fothergill (Mercer & Hole) explains.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review recent decisions on unreasonable conduct, costs awards and protective costs orders, highlighting the practical lessons for taxpayers and advisers.

Nick Wright

Nick Wright (Jerroms Miller) examines when family investment companies deliver tax savings, weighing incorporation costs, profit extraction and inheritance tax benefits against the consequences of an eventual exit.

Jill Gatehouse, Emily Szasz, Joe Williams, Tom Gardner

Jill Gatehouse, Emily Szasz, Joe Williams and Tom Gardner (Freshfields) examine HMRC’s proposed reforms to the taxation of distributions and their implications for capital returns, demergers and commercial transactions.

Rob Sharpe

Peter North

Rob Sharpe and Peter North (Cleary Gottlieb) consider how the new duty to correct may present challenges in the context of three common mechanisms for addressing tax risks in M&A transactions.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.