New anti-abuse provisions
In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more
The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more
As discussed in prior articles, there are several options for tax-incentivized giving, ranging from the informal and low-involvement to complex and highly involved structures. Many choose to adopt a more formal approach to...more
The Paris office of Hogan Lovells is pleased to provide this English language edition of our monthly e - newsletter, which offers a legal and regulatory update covering France and Europe for April 2018. ...more
Section 199A, enacted in the Tax Cuts and Jobs Act at the end of 2017, allows individuals and certain noncorporate taxpayers to deduct up to 20 percent of qualified business income (QBI) beginning in 2018. QBI generally...more