ANSON

HMRC’s updated guidance on the treatment of profits arising within, and distributions from, US LLCs is unsatisfactory in a number of respects, write Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).

Stuart Pibworth Will Smith Leonard Ng Chris Brause

Will Smith, Leonard Ng, Chris Brause and Stuart Pibworth (Sidley Austin) review recent developments within the investment funds industry which faces numerous challenges in the form of UK and international tax initiatives, as well as ongoing regulatory change.

Chris Morgan

Chris Morgan (KPMG) provides your monthly round-up of tax developments in the international arena, including BEPS; Anson; information exchange on cross-border tax rulings; proposals for a CCCTB; and an EU and global summary.

Rupert Shiers

Philip Harle

Philip Harle and Rupert Shiers (Hogan Lovells) review the HMRC’s guidance on Anson and consider its impact and future ramifications.

Mark Middleditch

Mark Middleditch (Allen & Overy) reports the latest tax developments that matter, including GAAP accounts and the concept of ‘fairly represents’; Julian Blackwell on CGT and enhancement expenditure; and HMRC’s response to Anson.

Allan Cinnamon

Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments, including trends influenced by BEPS.

HMRC has issued its response to the Supreme Court decision in George Anson v HMRC (2015) UKSC 44, confirming that it will continue with its existing practice to treat US LLCs as companies (see Revenue and Customs Brief 2015/15).

Allan Cinnamon

Allan Cinnamon (Cintax the Word Ltd) provides your monthly update.

Chris Morgan

Chris Morgan (KPMG) provides your monthly round-up of tax developments in the international arena, including: the implications of the Supreme Court's judgment in Anson and the Court of Appeal's second decision in BT Pension Scheme; the Corporate Tax Reform Act III in Switzerland; tax reform in Austria; proposed new corporate tax rules in Luxembourg; and tax changes in Greece.