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ANTI AVOIDANCE


Hartley Foster and Martin Caplice from the Tax Investigations and Disputes Team at DLA Piper, comment on Madeley & Finnigan v HMRC

Craig Thomson, senior manager, Deloitte's Tax Risk & Resolution Group discusses the recent Special Commissioners' case of Jade Palace v HMRC

Now that the Court of Appeal decision in this case has become final, John Carrell, of Farrer & Co, considers the lessons for those administering offshore companies

David Blumenthal, Tax Partner, Dewey Ballantine, describes the anti-avoidance rules on both sides of the Atlantic

Mark Schofield, Tax Partner, and Eric Peden, Tax Senior Manager, both of PricewaterhouseCoopers LLP in London discuss limitation on benefits and treaty qualification rules under the UK/US tax treaty

Carlos Ortiz, Partner, and Aileen Barry, Director, of DLA Piper Rudnick Gray Cary's New York and London Offices, respectively, examine the US & UK approach when monitoring tax compliance

Mark Schofield, tax partner, and Sophie Gimber, tax manager, of PricewaterhouseCoopers LLP, look at what consultation with industry means in the UK and US

Malcolm Edge, Chairman of KPMG's Tax practice, KPMG in the UK gives an overview of this special UK/US edition and discusses some of the wider issues surrounding the UK and US tax environments

Deborah Butler and George Bowden, both of the Internal Revenue Service, USA, describe the various mechanisms available to taxpayers to obtain advice from the Service regarding their tax obligations

Jim Sams, US Seconded Partner, and Sara Patel, Senior Manager, KPMG in the UK, set out some of the issues to consider for companies contemplating emigrating the UK or US

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