The government is consulting on a fundamental redesign of the stamp taxes on shares framework to create a new single self-assessed tax on securities. As part of the wider review of the UK funds regime, there is a consultation on the proposed scope and design of a new type of investment fund called the ‘reserved investor fund (contractual scheme)’. The FTT reaches a surprising conclusion in the Buckingham case on how much of a US dividend should be treated as income for UK tax purposes. The Court of Appeal agrees with the High Court in McClean v Thornhill KC that counsel did not owe a duty of care to the investors but, if there had been a duty of care, the Court of Appeal found (as obiter) that the unequivocal advice that the scheme ‘no doubt’ worked would have been negligent.
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The government is consulting on a fundamental redesign of the stamp taxes on shares framework to create a new single self-assessed tax on securities. As part of the wider review of the UK funds regime, there is a consultation on the proposed scope and design of a new type of investment fund called the ‘reserved investor fund (contractual scheme)’. The FTT reaches a surprising conclusion in the Buckingham case on how much of a US dividend should be treated as income for UK tax purposes. The Court of Appeal agrees with the High Court in McClean v Thornhill KC that counsel did not owe a duty of care to the investors but, if there had been a duty of care, the Court of Appeal found (as obiter) that the unequivocal advice that the scheme ‘no doubt’ worked would have been negligent.
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