SUPREME-COURT

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.

Constantine Christofi Craig Kirkham-Wilson Lauren Trask

Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.

Julius Konstantin Berling Liesl Fichardt Emily Au

Who proves what? Liesl Fichardt, Emily Au and Julius Konstantin Berling (Quinn Emanuel) set out how penalty appeals now divide the burden between HMRC and the taxpayer – and why the line between the two is far from settled.

Amelia Roffey

Henry Bennett-Gough

Stage three of the RMC test is where the real action now lies, writes Henry Bennett-Gough (Simmons & Simmons).

Paul Farey

Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.

Tim Sarson

Once again, the US dominates the international tax news cycle, reports Tim Sarson (KPMG).

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.

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.

Discretionary deferred profits via a corporate LLP were taxable as miscellaneous income

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.

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