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TAX POLICY ADMINISTRATION


Loviisa Langdon and Alexander Cox (Kirkland & Ellis) explain how the new carried interest rules apply to evergreen funds and highlight the complexities surrounding timing, valuation and average holding periods.

Matthew Rowbotham (Lewis Silkin) examines the Government’s consultation on double taxation for UK individuals in US LLCs and finds much to welcome, as well as some important issues still to resolve.
Alice Martin and Dr Carolyn Steppler (Charles Russell Speechlys) explain why excluding a settlor and spouse may not prevent CGT attribution after April 2025, and what reimbursement risks trustees must manage.
Card image Tom Margesson Elena Rowlands Ian Zeider
A low bar for ‘source’? Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) explain the Supreme Court’s decision in HFFX and its significance for LLP member remuneration.

Nick Wright (Jerroms Miller) considers how the new close company reporting regime changes the risk profile for alphabet shares, dividend planning and employee share arrangements in owner-managed businesses.

Dulcie Daly (Goodwin) considers the complexities that can arise for taxpayers when share sale proceeds include deferred amounts.

Catherine Hill (White & Case) questions whether the proposed tax adviser registration regime is a proportionate response to the Government’s aim of raising standards.
The Court of Appeal’s reasoning in Sintra Global misses key principles and authorities, writes Michael Firth KC (Gray’s Inn Tax Chambers).
Dr Michael Taylor (PwC) examines three recent cases where the FTT ignored the plain wording of legislation.
Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal decision in Lloyds Asset Leasing Ltd.
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