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International review for April 2024
Tim Sarson
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).
US limited liability corporations: updated HMRC guidance
Sebastian Prichard Jones
Andrew Crozier
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).
Tax and the City review for May 2023
Mike Lane
Zoe Andrews
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.
The Inflation Reduction Act 2022: less than promised?
Donald L Korb
Andrew Solomon
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.
International review for January 2022
Tim Sarson
Tim Sarson (KPMG) reports on a busy start to what promises to be an eventful year for the international tax world.
International review for January 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
What next for US tax policy?
Donald L Korb
Andrew Solomon
Donald L. Korb and Andrew Solomon (Sullivan & Cromwell) discuss President Biden's proposals for US tax policy.
International review for November 2020
Tim Sarson
Recent tax developments that matter from around the globe, reported by
Tim Sarson (KPMG).
International review for September 2020
Tim Sarson
Recent tax developments that matter from around the globe, reported by
Tim Sarson (KPMG).
Digitalisation: where are we headed?
Jefferson VanderWolk
Robert O'Hare
Robert O’Hare and Jefferson VanderWolk (Squire Patton Boggs) discuss the
current state of play and what needs to be resolved.
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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