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Andrew Goldstone and Katya Vagner (Mishcon de Reya) provide the monthly update on the latest tax developments affecting private clients.
With the UK’s continuing attractiveness as a holding company tax jurisdiction, Jonathan Cooklin and Dominic Foulkes (Davis Polk) consider the scope of technical UK tax issues that have a direct bearing on the drafting of merger agreements and related documents which implement these transactions.
The US Treasury recently issued new regulations to deter corporate ‘inversions’, where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction. Joseph Goldman and Anthony Whall (Jones Day) review their impact.
Andre Anthony (CMS Cameron McKenna) explains the tax issues arising on the importation of a private jet into the EU by a non-EU resident.

Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts

Priya Dutta answers a query on the tax residency of employees seconded to overseas offices and undertaking training in the UK

Carolyn Steppler and Jane Scott consider whether it may be easier for some individuals to become non-UK resident under the SRT, now the concept of a ‘clean break’ has been removed

Stephen Smith sets out the practical lessons from the Paul Daniel case concerning a taxpayer who realised a substantial capital gain whilst purporting to be working full-time abroad

From Peter Vaines, Squire Sanders, writing in UK Tax Bulletin, September 2013