RESTRUCTURING

Jade Du Berry Alan Rafferty Ollie Winters

The High Court has confirmed that HMRC do not have a veto over restructuring plans. Alan Rafferty, Jade Du Berry and Ollie Winters (Milbank) examine the implications of Waldorf, including HMRC’s constitutional arguments, the treatment of tax losses and the evolving approach to cross-class cram downs.

Abby Martin Lisa Rickelton Alex Lewis

HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.

Helena Kanczula

When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.

Paul Pritchard

Companies emerging from the pandemic may undertake a debt restructuring. Paul Pritchard (FTI Consulting) discusses current tax issues with debt releases.

Gavin Orpwood Louise Keegan Hannah McKenzie

Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the tax risks to international business operating models.

Matthew Mortimer

Kitty Swanson

Matthew Mortimer and Kitty Swanson (Mayer Brown) provide a practical guide.

Jonathan Rosen

Jonathan Rosen (Akin Gump Strauss Hauer & Feld) considers the recent restrictions on corporate interest deductibility, and their impact on the UK’s attractiveness as a holding company jurisdiction.

Darren Oswick

Gary Barnett

Darren Oswick and Gary Barnett (Simmons & Simmons) consider some of the tax implications that may result from the inevitable wave of business restructurings which will follow the Brexit vote.