Karen Cooper and Vicki Carr of Osborne Clarke review a common issue that can arise when private equity investors invest in small 'high risk' companies
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)
Jonathan Legg, Solicitor AIIT, Lawrence Graham LLP suggests that we should refocus the tax avoidance debate
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
James Dixon1 highlights the extraordinary breadth of situations considered by the Tribunals in their lifetime so far
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