The Educations Jobs and Medicaid Assistance Act 2010 was signed into US law on 10 August 2010. The Act amends several provisions of the Internal Revenue Code to restrict tax credits, and increase tax receipts.
Martin Bell examines the key tax issues for a UK corporate vendor to consider when selling a subsidiary
Pete Miller examines the effect the Bamberg case will have on transactions in securities
The ‘threat of recharacterisation’ of transactions where there are no direct comparables is ‘viewed as a significant blocker to corporate activity and growth’, AstraZeneca has claimed.
Debt cap regulations: do the clarifications to the 'available amount' go far enough?
The incorporation of a UK branch of an overseas company, or the overseas branch of a UK company, can result in chargeable gains. Robert Langston reviews the practical tax issues that should be considered
John Watson and Preena Patani use the Kellogg decision to point a way forward for the development of tax in the UK
Company reorganisations are increasingly popular to save compliance costs. David Brookes discusses some of the issues and pitfalls surrounding reorganisations and hive ups
What is the impact of HMRC’s revised guidance? Ed Dwan and Lucy Sauvage examine the current position
HMRC has published new draft guidance on situations where it will not usually review a company's residence status