DISTRIBUTION

Distributions from non-UK company not dividends of a capital nature

HMRC’s updated guidance on the treatment of profits arising within, and distributions from, US LLCs is unsatisfactory in a number of respects, write Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).

Helen Coward

Lewis Currie

Helen Coward and Lewis Currie (Charles Russell Speechlys) consider the consequences of unlawful distributions by UK companies, including the tax pitfalls to avoid.

David Whiscombe

David Whiscombe asks whether it is fair for a taxpayer to be effectively taxed twice on the basis of a mutually exclusive analysis of the same transaction.

Julie Howard

Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.

Mike Lane

Zoe Andrews

An FFT decision on unallowable purpose and a Supreme Court ruling on an EU law challenge are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).

Andrew Howard

Andrew Howard (Ropes & Gray) examines the decision that covers some fundamental questions of UK partnership tax.

Andrew Howard

Even by the standards of tax cases, the recent case of BlueCrest Capital Management Cayman Ltd & others v HMRC is a difficult read. However, it is worth persevering with, because HMRC has taken the opportunity to test out a number of theories on partnership taxation, with some fairly alarming results for taxpayers.

Ashley Greenbank

Ashley Greenbank (Macfarlanes) reviews the proposals on company distributions, which would amend the transactions in securities rules and introduce a new targeted anti-avoidance rule.

Jackie Wheaton

Question My client is a life tenant of a trust. The trustees hold 100% of the shares of a BVI company which has recently sold a major part of its business and now wishes to repurchase its own shares. The question has arisen as to whether the funds...

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