The U.K. government is set to introduce a new corporate criminal offence, based on the strict liability of the entity in question. It almost certainly will come into force in 2017, once the Criminal Finances Bill (Bill) is...more
12/23/2016
/ Associated Persons ,
Corporate Liability ,
Criminal Finances Bill ,
Criminal Liability ,
Financial Conduct Authority (FCA) ,
Fraud Prevention ,
HMRC ,
Public Interest ,
Risk Assessment ,
Risk Mitigation ,
Tax Evasion ,
UK
The U.K. government expands its crackdown on tax evaders and the persons who assist them, by targeting businesses who fail to prevent tax evasion....more
12/22/2016
/ Corporate Liability ,
Criminal Fascilitation ,
Criminal Liability ,
Criminal Penalties ,
Due Diligence ,
Employee Training ,
Foreign Tax ,
Fraud Prevention ,
Fund Managers ,
HMRC ,
Indemnity Agreements ,
Investors ,
Risk Assessment ,
Senior Managers ,
Tax Evasion ,
Third-Party Service Provider ,
UK ,
UK Bribery Act ,
White Collar Crimes
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
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
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
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
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
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