ANALYSIS

Cutting edge analysis on tax issues.

Jisun Choi

Moshe Spinowitz and Jisun Choi (Skadden) assess the growing attractions of a US parent company following tax reforms and the Side-by-Side package, explaining the trade-offs and complexities involved in relocating.

David Gordon

Writing on behalf of The 100 Group’s Tax Committee, David Gordon calls for stable business taxes, simpler rules and wider access to advance tax certainty to help the UK compete for investment.

Paul Rattew

John Endacott

John Endacott and Paul Rattew (PKF Francis Clark) examine proposed reforms to company distributions and the taxation of value extracted by private shareholders.

Joe Robinson

Harvey Innocent

Joe Robinson and Harvey Innocent (Macfarlanes) explain how LLP members may defer gains when transferring their interests to a company, while highlighting additional complications for corporate members and goodwill.

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Lombard Odier) reflects on potential changes to tax policymaking, landlord registration, HMRC’s scrutiny of cryptoassets and adviser conduct, and a recent domicile decision.

Nigel Watson

Claire Withers

With speculation over the alignment of CGT and income tax rates, Claire Withers and Nigel Watson (Burges Salmon) ask what that would mean for employee equity and which policy choices it would leave unresolved.

Andrew Page

Andrew Page OBE (formerly HMRC) argues that the denial of relief for windfarm survey costs exposes a gap between the rules for capital allowances and intangible assets.

David Pett

David Pett (Temple Tax Chambers) writes that the FTT in CooperVision has ‘muddied the waters’ and made it more difficult to advise on whether shares are employment-related securities.

Matthew Mortimer

Elmira Jazottes

Matthew Mortimer and Elmira Jazottes (Mayer Brown) assess the impact of recent VAT decisions and changes to the UK tax net on the taxation of receivables finance structures.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) review recent developments including the latest GloBE package, Hunt on the limits of judicial correction, a timely reminder of the significant contribution made by the financial services, and the UTT implications of HMRC’s VAT guidance on fund management.

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