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ANALYSIS

Cutting edge analysis on tax issues.

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) looks at the decisions in Beard and Rettig, as well as HMRC’s revised guidance on unallowable purpose.
As the Senate prepares to take up President Trump’s sweeping tax and spending package, Andrew Solomon (Sullivan & Cromwell) considers its key provisions and what happens next.
Kate Garcia and Thomas Wilkinson (Shoosmiths) review the consultation on the potential redesign or reform of penalties imposed for inaccuracies in tax returns and failures to notify.
UK reforms to the permanent establishment rules and the Investment Manager Exemption could reshape the tax treatment for non-resident funds and UK investment managers, write James Anderson and Lorenza De Domenico (Skadden).
David Pickstone and Anastasia Nourescu (Stewarts) consider the Government’s proposed reform of the landfill tax regime and its impact on industry.
Mark Bevington (ADE Tax) highlights the areas where the new TP and UTPP rules do not appear to work as intended.
Peter Nias and Ben Elliott (Pump Court Tax Chambers) consider a recent practice statement and other measures supporting the greater use of ADR.
This month’s review by Joao Martinho and Gary Barnett (Simmons & Simmons) covers the Court of Appeal decision in Impact Contracting Solutions and two recent cases on the meaning of consideration.
Naomi Lawton (A&O Shearman) finds much to welcome in the Government’s latest policy statements.
Adam Craggs and Liam McKay (RPC) examine the current consultation which could help influence HMRC’s future approach to dispute resolution.
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