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Tax Treaty HMRC

Cadwalader, Wickersham & Taft LLP

Burlington: Good News for the Secondary Debt Market

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

Cadwalader, Wickersham & Taft LLP

Haworth: Residency Tie-Breaker Tests in a ‘Round the World’ Tax Scheme

The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...more

Proskauer - Tax Talks

COVID-19: OECD updates its guidance on residence and permanent establishments

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From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk. In April 2020 the OECD...more

Freeman Law

International Tax Treaty: The United Kingdom

Freeman Law on

Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more

Katten Muchin Rosenman LLP

UK to Tax Real Estate Capital Gains of Non-UK Investors

On 6 July 2018, the UK Government published draft legislation to extend the territorial scope of UK tax by bringing capital gains realised by non-UK resident investors from UK real estate within the scope of UK taxation with...more

Proskauer - Tax Talks

UK Finance Bill 2019 published – UK commercial property tax regime for non-resident investors to change, but some relief for...

Proskauer - Tax Talks on

On 6 July 2018 the UK Finance Bill 2019 was published by the UK Government. The draft Finance Bill contains the details of the new regime on taxation of non-UK resident investors in UK real estate that had been proposed in a...more

Morrison & Foerster LLP

The UK Double Tax Treaty Passport Scheme – Changes for the UK Loan Market

The UK Double Tax Treaty Passport (“DTTP”) scheme has recently been extended by HM Revenue & Customs (“HMRC”) to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme. The aim of the amendments is...more

Proskauer Rose LLP

Tax Round Up - April 2017

Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Proskauer - Tax Talks

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Bilzin Sumberg

Change in the UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

Bilzin Sumberg on

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Key Takeaways: Delaware LLCs - The Implications of Anson"

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

Morgan Lewis

Recent UK Court Decision on UK Tax Treatment of US LLCs

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HMRC provides guidance on the implications of the recent case Anson v Revenue and Customs Commissioners. Delaware limited liability companies (LLCs) are regularly seen in many international corporate groups, including in...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson"

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

Latham & Watkins LLP

UK Supreme Court Forces HMRC to Rethink its Tax Treatment of Delaware LLCs

Latham & Watkins LLP on

Supreme Court rules in favour of taxpayer in landmark case regarding UK tax treatment of Delaware LLCs. On 1 July 2015, the UK Supreme Court handed down a long-awaited ruling in the case of Anson v Commissioners for Her...more

Locke Lord LLP

UK Supreme Court Decision in Anson v. HMRC Reverses Established Tax Treatment of US LLCs

Locke Lord LLP on

In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more

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