New anti-abuse provisions
Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more
UK General Tax Developments - HMRC updates guidance on what constitutes "ordinary share capital" - Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this...more
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more
Draft clauses to introduce a new general anti-abuse rule (GAAR) into the UK tax code were published as part of the Finance Bill 2013 on 11 December 2012. Some form of general anti avoidance rule was first seriously canvassed...more