Daniel Hawthorne

Daniel Hawthorne

Dechert LLP

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Latest Posts › Double Taxation


UK tax treatment of US LLC: HMRC’s practice following Anson

We reported earlier this year on the UK Supreme Court’s decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to claim relief against his UK tax liabilities for US tax paid on his share of...more

10/1/2015 - Anson v HMRC Business Taxes Double Taxation HMRC LLC UK UK Supreme Court

Financial Services Tax – UK Update from Dechert’s Tax Group: Rule Changes Yield Mixed Blessings for UK Investors in Offshore Funds

UK investors in closely held offshore funds can be directly liable for tax if the fund makes a gain on an underlying asset even if the gain is reinvested by the fund and not distributed to the investor. There is also the...more

2/11/2013 - Capital Gains Double Taxation Investors Liquidation Offshore Funds Privately Held Corporations

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