News & Analysis as of October 12, 2024

HMRC

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Burlington: Good News for the Secondary Debt Market

Cadwalader, Wickersham & Taft LLP on 7/29/2024

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

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

Cadwalader, Wickersham & Taft LLP on 6/3/2024

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

UK Tax Round Up - March 2023

Proskauer Rose LLP on 3/20/2023

Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more

Good v HMRC – What Does ‘Entitled To’ Mean?

Cadwalader, Wickersham & Taft LLP on 2/27/2023

The Court of Appeal in Good v HMRC [2023] EWCA Civ 114 upheld the decision of the Upper Tribunal in examining the meaning of “entitled to” in the context of Section 611 of the Income Tax (Trading and Other Income) Act 2005...more

UK Tax Round Up - October 2022

Proskauer Rose LLP on 11/1/2022

Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more

BlueCrest FTT Decision – Salaried Member Rules and Asset Managers

Proskauer - Tax Talks on 7/14/2022

The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more

UK Tax Round Up - December 2019

Proskauer Rose LLP on 1/6/2020

UK Case Developments - IR35 – no mutuality of obligation to create a contract of employment - RALC Consulting Ltd v HMRC has provided the First-tier Tribunal (FTT) with another opportunity to consider the application...more

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Skadden, Arps, Slate, Meagher & Flom LLP on 1/22/2016

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

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