The Tax Journal brings you extracts from Ernst & Young's 2007 Budget Alert. Ernst & Young's comments are in italics
Ian Latter, Partner, and Neil O'Brien, Director, KPMG's UK M&A Tax team, explain the potential benefits of the increasingly popular 'Opco/Propco' structure in the context of M&A and discuss the related tax hazards
David Pett, Tax Partner at Pinsent Masons, writes about a new form of employee share incentive scheme arrangement, the executive shared ownership plan (ExSOP)
Rupert Shiers of McGrigors LLP and Pete Miller of Ernst & Young LLP review the history and interpretation of 'whole or main' purpose test
Theodore D Setzer, Special Counsel, IRS Office of Associate Chief Counsel (International), gives us an IRS view of tax avoidance
Rachel Morrison, Director of Group Taxation & Accounting at Alliance & Leicester plc, presents an industry perspective of tax avoidance
In the second of two articles, Richard Fletcher and Geoffrey Kay, Baker & McKenzie LLP, consider the OECD Report on the Attribution of Profits to Permanent Establishments
Jeremy Edwards and Liana Coyne of Baker & McKenzie LLP's London Employee Benefits Group review some recent developments affecting NICs
Jonathan Fisher QC, In-House Counsel, McGrigors LLP, discusses the implications of the Serious In Crime Bill 2007 for tax practitioners
Philip Broadley, The Hundred Group and Richard Collier-Keywood, PricewaterhouseCoopers,1 report on the findings of The Hundred Group's survey of its members' UK tax bills