The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).
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).
In their latest review, Mike Lane and Zoe Andrews (Slaughter and May) consider two new consultations and a surprising decision on the UK taxation of a US dividend.
Donald L. Korb and Andrew Solomon (Sullivan & Cromwell) review the US legislation designed to support climate and health care initiatives, which contains three significant tax-raising provisions.
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