Sean Finn

Sean Finn

Latham & Watkins LLP

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The Panama Effect: UK Government accelerates proposals to criminalise failure to prevent tax evasion

10 considerations for professionals and corporates worldwide in advance of the new law. Overview - In a move widely seen as a response to the so-called “Panama Papers” revelations, the UK Government has enhanced...more

4/27/2016 - Consultation Periods Criminal Liability Due Diligence Foreign Tax Multinationals Panama Papers Proposed Legislation Risk Assessment Tax Evasion Third-Party UK UK Bribery Act

Draft UK Income-based Carried Interest Legislation Published

Proposed new UK rules will tax carried interest in certain funds as income, with only specified funds entitled to capital gains treatment - The UK government published draft legislation on 9 December 2015 amending the...more

2/8/2016 - Anti-Avoidance Asset Management Capital Gains Carried Interest Carried Interest Tax Rates Proposed Regulation Tax Exemptions UK

European Commission Proposes an Anti-Tax Avoidance Directive

The proposed Council Directive marks another, significant, though likely problematic, step towards tackling tax avoidance across Member States. Background - The European Commission (the Commission) has been moving...more

2/5/2016 - BEPS Controlled Foreign Corporations EBITDA EU European Commission Exit Tax GAAR OECD Tax Avoidance

HMRC Responds to Landmark Case on UK Tax Treatment of Delaware LLCs

Business as usual for UK taxpayers following Supreme Court decision in Anson v HMRC? HM Revenue and Customs (HMRC) has published its response to the UK Supreme Court’s decision in the landmark double taxation case of...more

11/19/2015 - Anson v HMRC Double Taxation Limited Liability Companies Tax Treaty UK UK Supreme Court

OECD Publishes Final BEPS Project Reports

A focus on hybrid arrangements, interest deductions, treaty abuse and permanent establishment structures. On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit...more

10/22/2015 - BEPS EBITDA G20 Interest Payments Multinationals OECD Tax Avoidance Tax Treaty

UK Supreme Court Forces HMRC to Rethink its Tax Treatment of Delaware LLCs

Supreme Court rules in favour of taxpayer in landmark case regarding UK tax treatment of Delaware LLCs. On 1 July 2015, the UK Supreme Court handed down a long-awaited ruling in the case of Anson v Commissioners for Her...more

8/14/2015 - Anson v HMRC Double Taxation HMRC Limited Liability Companies Tax Treaty UK UK Supreme Court Venture Funding

UK Tax Shake Up for Partnerships

In light of tax changes proposed for April 2014, partnerships may need to reconsider their members’ classification and/or duties to maintain the most tax efficient positions. The UK Government’s recently published...more

12/20/2013 - AIFM AIFMD EU Income Taxes Limited Liability Partnerships Partnerships Profits UK Wages

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