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Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Faegre Drinker Biddle & Reath LLP

The Return of Crown Preference — Implications for Borrowers and Lenders

The first day of December witnessed an early visit from the ghost of Christmas past for the rules relating to the order of priority on insolvency. For insolvencies commenced on or after 1 December 2020, Her Majesty’s Revenue...more

Goodwin

The Return of Crown Preference on 1 December, 2020

Goodwin on

The return of Crown Preference on 1 December, 2020 has widely united the restructuring community against the new measures. Whilst the rationale that the Treasury should have priority for sums received by a debtor on its...more

K&L Gates LLP

COVID 19: UK Insolvency Reform – Crown Preference Returns From 1 December 2020

K&L Gates LLP on

EXECUTIVE SUMMARY - On a UK company’s insolvency, the UK tax authority (HMRC) will become a preferential creditor in respect of certain unpaid taxes (Crown Preference) with effect from 1 December 2020. Despite lobbying...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Proposes Preferential Status for Certain Taxes in Insolvencies

The U.K. government is proposing to reintroduce preferential status to certain taxes in U.K. insolvencies beginning 6 April 2020. If enacted: - certain taxes owed to HM Revenue & Customs (HMRC) would rank ahead of floating...more

Proskauer Rose LLP

UK Tax Round Up - June 2018

Proskauer Rose LLP on

Streaming of losses on trade succession (Leekes v. HMRC) - This case involved a taxpayer who purchased a business (the "predecessor business") and combined it with their existing business (creating the "enlarged...more

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