James Anderson

James Anderson

Skadden, Arps, Slate, Meagher & Flom LLP

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"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

1/22/2016 - Capital Gains Carried Interest EU Executive Compensation France Germany HMRC Income Taxes Management Fees Managers Private Equity Tax Liability UK

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

10/7/2015 - Anson v HMRC Business Taxes Delaware Limited Liability Company Act Dividends Double Taxation Foreign Corporations HMRC Limited Liability Company (LLC) LLC Agreements Tax Credits Tax Treaty UK UK Supreme Court

"Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson"

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border...more

9/29/2015 - Anson v HMRC BEPS CFC Cross-Border Transactions Double Taxation Entity Classification HMRC Legal Entity Identifiers Limited Liability Company (LLC) Tax Policy Tax Treaty UK UK Supreme Court

A Guide to the UK Disguised Investment Management Fee Rules

New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...more

4/8/2015 - Carried Interest Clawbacks Distribution Rules Fees Financial Transaction Tax Fund Managers Hedge Funds HMRC Income Taxes Investment Management Limited Partnerships Non-Resident Aliens UK

"Taxpayer Naming – The Future of UK Tax Compliance?"

As part of Autumn Statement 2013, HM Revenue & Customs (HMRC) has today publicly named the banks that have newly adopted or readopted the Code of Practice on Taxation for Banks (the Code)....more

12/5/2013 - Banks EU HMRC UK

"HMRC Turns Up the Pressure on UK LLPs"

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

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