Shares

The scope of negative earnings is almost certainly wider than has generally been appreciated, writes Nigel Doran (Macfarlanes).

Dominic Stuttaford

Greg Branagan

The UK government published a consultation document setting out proposals for further changes to the calculation of consideration for stamp duty and SDRT purposes. Dominic Stuttaford and Greg Branagan (Norton RoseFulbright) review the proposals.

Jonathan Cooklin

Dominic Foulkes

Dominic Foulkes and Jonathan Cooklin (Davis Polk) share their approach to understanding some of the tax issues.

David Pett

Determining whether shares are held as employment-related securities is not always straightforward. David Pett (Temple Tax Chambers) takes a closer look.

Gareth Miles

Gareth Miles (Slaughter and May) considers how the proceeds of a buy-side W&I insurance policy may be taxed in the UK.

Perminder Gainda

Josh Lom

Josh Lom and Perminder Gainda (Herbert Smith Freehills) consider the decisions in McQuillan and Castledine, where the tribunals took different approaches to the meaning of ‘ordinary share capital’.

Adrian Brettell

Heather Corben

Heather Corben and Adrian Brettell (King & Wood Mallesons) consider the legislative history of FA 1986 s 77, the practical problems caused by using the wider meaning of stock and the revised Stamp Office interpretation causing difficulties in obtaining the relief.

Simplification is long overdue, claim Paul Emery & Suzi Edwards (PwC)

Mark Middleditch

Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual