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ANALYSIS
Cutting edge analysis on tax issues.
Private client review for November 2024
Klara Kronbergs
Edward Reed
In this month’s review, Edward Reed and Klara Kronbergs (Macfarlanes)
consider some of the more nuanced aspects of the non-dom reforms, as well
as some key tribunal decisions affecting private clients.
Tax, memory and the written record: revisiting Gestmin
Gerald Montagu
Elmira Jazottes
Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.
Annual Tax on Enveloped Dwellings
David Wright
ATED is an unconventional and surprisingly complicated tax.
David Wright (ATT) recaps the basics and looks at the available reliefs.
Tax and the City review for November 2024
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine the impact of the Autumn Budget and some recent tribunal decisions on the financial sector.
FINs: a licence to fish?
David Haworth
Rose Swaffield
Financial institution notices represent a greater power for HMRC, but this does not mean that tax managers’ hands are tied, write David Haworth and Rose Swaffield (Freshfields).
Criminal prosecutions: nobody expects the (tax) inquisition
Siobhan Gillespie
George Gillham
George Gillham and Siobhan Gillespie (Fieldfisher) assess HMRC’s track record.
Non-doms post-Budget: where are we now?
Helen McGhee
Lynnette Bober
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) provide an
overview of the new rules and highlight some key points to watch.
Structuring following the new rules for IHT business and agricultural property reliefs
Michael Thomas KC
Diversifying ownership will become an increasingly important strategy in
light of the new restrictions to APR and BPR, writes Michael Thomas KC
(Pump Court Tax Chambers).
Autumn Budget 2024: private capital
Elena Rowlands
Ian Zeider
Tom Margesson
Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) consider
the impact on the private capital sector, focusing on the changes announced to
the taxation of carried interest.
Alternative dispute resolution and mediation
Adam Craggs
Liam McKay
We are likely to see a consistent increase in the use of mediation in tax
disputes. Adam Craggs and Liam McKay (RPC) explain when and how it is
in the taxpayer’s interests.
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Energy security investment mechanism: average prices
Reporting of offshore interest
Further lifetime allowance changes
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
CGT anti-forestalling measures
Pensions tax changes in the Budget
Collins Construction Ltd v HMRC
Syngenta Holdings Ltd v HMRC
National Farmers' Union calls for reversal of IHT reforms