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ANALYSIS
Cutting edge analysis on tax issues.
The Upper Tribunal’s ruling in Gould on interim dividends
Dominic Stuttaford
Aiden Hepworth
Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright) assess the
practical impact of the Upper Tribunal’s decision in Gould.
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.
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way