Tax Journal

Matthew Rowbotham

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.

Mike Lane

Zoe Andrews

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the HFFX decision on LLP deferred remuneration, HMRC’s distributions consultation, the Barclays case on VAT grouping and the credit-management exemption in securitisations.

Andrew Howard

Omar Asfar

Andrew Howard and Omar Asfar (Ropes & Gray) examine the employment-related securities and valuation lessons from the tribunal’s decision, including the limits of third-party deal pricing and the high bar for protection offered by professional advice.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review recent procedural decisions on strike out, costs for HMRC’s pre-appeal conduct and disclosure, drawing out the practical risks for tax litigants.

Alice Martin

Carolyn Steppler

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.

Chris Sanger

A useful release valve or a source of consultation overload? Chris Sanger (EY) examines how Tax Update days have become part of the UK tax policy cycle.

A report by Lexis®+UK Tax

Elena Rowlands, Tom Margesson, 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.