Following the announcement in Budget 2013, HM Revenue & Customs (HMRC) issued a consultation document on May 20, 2013 that focuses on two areas of partnership taxation where HMRC perceive “unintended inconsistencies”...more
5/22/2013 - AIFMD EU HMRC LLPs Lost Profits Partnerships Profits Tax Planning
In this article we consider some alternative approaches to the proposed U.K. status of “employee shareholders,” who receive capital gains tax-exempt shares in their employer (or its parent) in return for waiving certain...more
5/14/2013 - Capital Gains Corporate Taxes Employee Shareholders EU Tax Exemptions Valuation
Summary - In an eagerly awaited decision of the U.K. Supreme Court in the case of R (on the Application of Prudential plc and Another) v. Special Commissioner of Income Tax and Another, [2013] UKSC 1, legal advice...more
1/25/2013 - Accountants Appeals EU Legal Advice Privilege
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