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US-TAX-POLICY
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
Andrew Solomon
During Trump’s second presidential term, the spectre of tax cuts expanding the US federal budget deficit will fuel fierce debates between fiscally conservative and ‘pro-growth’ Republicans, write Donald L Korb and Andrew Solomon (Sullivan & Cromwell).
The Trump effect: US foreign tax policy
Tanja Velling
Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).
International review for November 2024
Tim Sarson
The tax policies of President-elect Trump and the new European Commission are among the recent developments reviewed by Tim Sarson (KPMG).
The Court of Appeal favours form over function in GE Financial
Kyle Rainsford
In
GE Financial Investments
, the Upper Tribunal favoured the functional
interpretation while the Court of Appeal favoured the territorial, writes
Kyle Rainsford (Addleshaw Goddard).
Judicial developments in recent treaty cases
David Goldberg QC
Constantine Christofi
Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
GE Financial Investments v HMRC
Residence and the UK/USA double tax treaty.
Self's assessment: signs of a ceasefire in the digital trade war?
Heather Self
In our continuing series, Heather Self reviews tax issues that make the headlines in the national press. This week, the impact of the new US proposals on international tax reform.
US tax reform: recent changes and next steps
Mark Saunderson
Miles Humphrey
Mark Saunderson and Miles Humphrey (Deloitte) examine what has happened since the Tax Cuts and Jobs Act was passed.
International review: looking back on 2019
Tim Sarson
Tim Sarson (KPMG) reviews some of the interesting developments that
unfolded over the past year in the international tax arena.
US tax reform: examining the Tax Cuts and Jobs Act of 2017
Donald L Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) examine the result of the year-long US tax reform effort, the Tax Cuts and Jobs Act of 2017.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
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TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime