ANALYSIS

Cutting edge analysis on tax issues.

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.

Alexander Cox

Loviisa Langdon

Loviisa Langdon and Alexander Cox (Kirkland & Ellis) explain how the new carried interest rules apply to evergreen funds and highlight the complexities surrounding timing, valuation and average holding periods.

A detailed report of this year’s Legislation day, with additional practitioner comment.

Matthew Rowbotham

Matthew Rowbotham (Lewis Silkin) examines the Government’s consultation on double taxation for UK individuals in US LLCs and finds much to welcome, as well as some important issues still to resolve.

Carolyn Steppler

Alice Martin

Alice Martin and Dr Carolyn Steppler (Charles Russell Speechlys) explain why excluding a settlor and spouse may not prevent CGT attribution after April 2025, and what reimbursement risks trustees must manage.

Elena Rowlands Ian Zeider Tom Margesson

A low bar for ‘source’? Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) explain the Supreme Court’s decision in HFFX and its significance for LLP member remuneration.

Claire Logan

Claire Logan (Grant Thornton) explains why estoppel and abuse of process are increasingly relevant in VAT disputes and how they can materially affect how cases are argued and resolved.

Nick Wright

Nick Wright (Jerroms Miller) considers how the new close company reporting regime changes the risk profile for alphabet shares, dividend planning and employee share arrangements in owner-managed businesses.

Veronika Lipinska

Matthew Emms

Matthew Emms and Veronika Lipinska (BDO) consider whether, following the 2025 Budget reforms, a CSOP should now revert to EMI, and in what circumstances CSOP or unapproved options might still be relevant.