Introduction -
After a long gestation, the much heralded new UK fund structure, the Reserved Investor Fund (“RIF”) is finally expected to be available from 19 March 2025....more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2024 on 30 October 2024. The Budget was the first to be delivered by the new Chancellor of the Exchequer, following the election of the Labour...more
The Chancellor of the Exchequer delivered the United Kingdom (UK) Spring Budget for 2024 on 8 March 2024. The Budget was delivered against the backdrop of an anticipated general election in the summer or autumn of 2024 and...more
4/2/2024
/ Alternative Investment Funds ,
Anti-Avoidance ,
Budgets ,
Commercial Real Estate Contracts ,
Investment Schemes ,
Non-Domiciled Investors ,
Real Estate Investments ,
Real Estate Market ,
Stamp Duty Land Tax ,
Tax Liability ,
UK
Key Tax Measures The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Spring Budget for 2024 on 8 March, 2024.
The Budget was delivered against the backdrop of an anticipated general election in the summer...more
3/8/2024
/ Domicile ,
Film Industry ,
Financial Institutions ,
Income Taxes ,
Independent Films ,
Insurance Industry ,
Investment Funds ,
Investors ,
Policy Terms ,
Proposed Legislation ,
Real Estate Investments ,
Stamp Duty Land Tax ,
Tax Credits ,
Transfer of Assets ,
UK
In many respects, the Upper Tribunal’s decision in Hargreaves Property will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to...more
As part of the Spring 2023 Budget, Chancellor Jeremy Hunt has scrapped plans to require sovereign wealth funds to pay corporation tax on property and commercial enterprises.
The United Kingdom (“UK”) government had...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023.
The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023.
The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more
Market overview -
Few could have predicted the unexpected twists and turns 2022 would provide. A year in which the spectre of war came home to haunt Europe....more
The UK Government has announced wide ranging reforms to the UK financial services industry, including key tax reforms -
On 9 December 2022, the UK Chancellor of the Exchequer, Jeremy Hunt, announced the “Edinburgh...more
As we draw close to the end of the year, we take a moment to revisit some of the taxation changes announced in the Autumn budget, with some of these being implemented in the upcoming tax year in April 2022. ...more
In the final part of this four-part series, we explore some of the common issues that may arise in limited recourse structures, as well as ways to address or mitigate the risks and costs....more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Autumn Budget for 2021 on 27 October 2021.
The Budget was delivered against the backdrop of the UK’s ongoing recovery from the Covid‑19 pandemic and the...more
10/28/2021
/ Bank Holding Company ,
Budgets ,
Corporate Taxes ,
HMRC ,
International Tax Issues ,
REIT ,
Securitization Market ,
Tax Avoidance ,
Tax Rates ,
Tax Reform ,
UK
Business Tax Provisions -
About-Face on Deductibility of PPP Expenses. The CAA overrules the IRS’s previous guidance denying the deductibility of expenses relating to forgiven PPP loans....more
2/3/2021
/ CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Families First Coronavirus Response Act (FFCRA) ,
Federal Loans ,
Financial Stimulus ,
Infectious Diseases ,
New Legislation ,
Paycheck Protection Program (PPP) ,
SBA Lending Programs ,
Tax Credits ,
Tax Deductions ,
Tax Planning
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2020 on 11 March 2020. The Budget was delivered against a backdrop that very few people could have anticipated at the commencement of the year....more
3/12/2020
/ Budgets ,
Business Income ,
Corporate Taxes ,
Digital Services Tax ,
Foreign Investment ,
General Partnerships ,
HMRC ,
Investment Funds ,
Limited Liability Partnerships ,
Non-Residents ,
Property Tax ,
Real Estate Investments ,
Stamp Duty Land Tax ,
Tax Avoidance ,
Tax Planning ,
Tax Rates ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more
11/1/2018
/ Anti Tax Avoidance Directive (ATAD) ,
Anti-Avoidance ,
Budgets ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Digital Taxes ,
Diverted Profits Tax ,
EU Directive ,
Hybrid Capital Instruments ,
Income Taxes ,
Internet Retailers ,
Royalties ,
Search Engines ,
Social Media ,
Stamp Duty Land Tax ,
Tax Deductions ,
Tax Rates ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
The Chancellor of the Exchequer delivered the UK Budget for 2017 on 22 November 2017. Delivered against the backdrop of the UK’s ongoing negotiations to exit from the European Union, the Budget featured a significant...more
11/29/2017
/ Collective Investment Schemes ,
Corporate Taxes ,
Federal Budget ,
Income Taxes ,
International Tax Issues ,
Tax Avoidance ,
Tax Policy ,
UK ,
UK Brexit ,
Value-Added Tax (VAT) ,
Venture Capital
The Chancellor of the Exchequer's first Autumn Budget under the new budget timetable, which sees the Autumn Statement replaced with an Autumn Budget (and the Spring Budget replaced with a Spring Statement), will be announced...more
On 30 September 2017, Part 3 of the UK Criminal Finances Act 2017 (the “CF Act”) came into force creating new corporate offences for failing to prevent the facilitation of UK or overseas tax evasion. Similar to the standard...more
In its referendum held on 23 June 2016, the UK voted to leave the European Union (“Brexit”). On the following day, David Cameron announced that he will resign as Prime Minister on the election of a new Conservative Party...more
6/28/2016
/ Capital Requirements Regulation (CRR) ,
Collateralized Loan Obligations ,
EU ,
EU Passport ,
European Economic Area (EEA) ,
Financial Markets ,
Member State ,
MiFID ,
Popular ,
Referendums ,
Risk Retention ,
Securitization Market ,
UK ,
UK Brexit
The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more
3/18/2016
/ Banking Sector ,
BEPS ,
Corporate Taxes ,
EBITDA ,
Federal Budget ,
International Tax Issues ,
OECD ,
Popular ,
Securitization ,
Tax Avoidance ,
UK ,
Withholding Tax
On 3 December 2015 the Luxembourg President of the Council of the European Union released a “state of play” announcement on the progress made during the course of this year by the ten European Union participating member...more
The Chancellor of the Exchequer delivered his budgetary Autumn Statement on 25 November 2015. In this Client and Friends Alert we have outlined the key tax measures that we expect to be of interest to Cadwalader’s clients...more
The Chancellor of the Exchequer’s first Budget of the new Parliament, delivered on 8 July 2015, will be remembered as a reforming Conservative budget, including significant changes to the United Kingdom’s welfare provisions...more
7/10/2015
/ Bank Taxes ,
Corporate Taxes ,
Derivatives ,
Financial Institutions ,
Foreign Corporations ,
GAAR ,
HMRC ,
Loans ,
Tax Avoidance ,
Tax Credits ,
Tax Cuts
The Chancellor of the Exchequer’s final Budget of the current Parliament, given on 18 March 2015, was held in the shadow of the UK’s general election on 7 May 2015. With the backdrop of the UK’s GDP growth increasing,...more