News & Analysis as of

Insolvency HMRC

Latham & Watkins LLP

Charging Ahead: Grappling With the Characterisation of Fixed and Floating Charges

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The characterisation of fixed and floating charges remains a complex area, not least with respect to new intangible asset types. The key distinction between a fixed and a floating charge is well established as a matter of...more

Latham & Watkins LLP

Directors Duties Post-Sequana More Light at the End of the Tunnel

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A recent decision has helped to frame the tests articulated by the Supreme Court in Sequana. The Supreme Court’s landmark decision in Sequana[2022] UKSC 25.leaves many unanswered questions, and finding a common thread...more

BCLP

Fair's fair: the concept of fairness in Part 26A Restructuring Plans

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Since its inception under CIGA 2020, there has been no shortage of legal commentary on the effectiveness of the legislation governing Part 26A Restructuring Plans, and the ways in which the judiciary have interpreted and...more

Dechert LLP

Fixed to Floating Charge Security: Exploring the Spectrum of Control

Dechert LLP on

In the recent case of Avanti Communications, the English Court held that to constitute fixed charge security, a chargee’s control over the relevant charged assets does not need to be absolute. A significant amount of control...more

Hogan Lovells

Its (not) a GAS: UK High Court refuses to sanction HMRC-cramming restructuring plan

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HMRC has successfully opposed a restructuring plan (“Plan”) brought by The Great Annual Savings Company Limited (“GAS” or “the Company”) under which HMRC would have been crammed down as a dissenting creditor. The Court held...more

Cadwalader, Wickersham & Taft LLP

Crammed Down but Not Out: HMRC Successfully Opposes Restructuring Plans

HMRC has recently taken an increased interest in opposing restructuring plans under Part 26A of the Companies Act 2006 (“Part 26A”) under which HMRC would otherwise be crammed down. This follows HMRC somewhat regaining its...more

Hogan Lovells

Judgment reserved on Houst’s potential HMRC cram

Hogan Lovells on

Judgment has been reserved on the sanction of Houst Ltd’s restructuring plan at a hearing held in front of Zacaroli J on Friday morning (15 July 2022), while the company gathers the further valuation information requested by...more

Katten Muchin Rosenman LLP

The UK Government and HMRC's Efforts to Clamp Down on Promoters of Tax Avoidance

Tax avoidance is the process of manipulating tax rules to reduce the amount of tax payable and obtaining a financial advantage that was never the intention of the legislation. A typical example of tax avoidance involves the...more

Jones Day

Restoration of Crown Preference and Erosion of the English Floating Charge

Jones Day on

With effect from December 1, 2020, Her Majesty's Revenue and Customs ("HMRC") ranks ahead of floating charge holders and unsecured creditors with respect to recovering certain pre-insolvency taxes from an insolvent business...more

Akin Gump Strauss Hauer & Feld LLP

Tax 2020: Developments Affecting Financial Restructurings

During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial restructurings and corporate reorganizations. There have also been other...more

Faegre Drinker Biddle & Reath LLP

The Return of Crown Preference — Implications for Borrowers and Lenders

The first day of December witnessed an early visit from the ghost of Christmas past for the rules relating to the order of priority on insolvency. For insolvencies commenced on or after 1 December 2020, Her Majesty’s Revenue...more

Goodwin

The Return of Crown Preference on 1 December, 2020

Goodwin on

The return of Crown Preference on 1 December, 2020 has widely united the restructuring community against the new measures. Whilst the rationale that the Treasury should have priority for sums received by a debtor on its...more

K&L Gates LLP

COVID 19: UK Insolvency Reform – Crown Preference Returns From 1 December 2020

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EXECUTIVE SUMMARY - On a UK company’s insolvency, the UK tax authority (HMRC) will become a preferential creditor in respect of certain unpaid taxes (Crown Preference) with effect from 1 December 2020. Despite lobbying...more

Dechert LLP

COVID-19 Coronavirus Business Impact – proposed Coronavirus Job Retention Scheme taxation and clawback regime announced

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In this OnPoint we report on the UK Government’s recently announced consultation on the taxation and clawback regime which will apply in relation to grants made to employers under the Coronavirus Job Retention Scheme (“the...more

Morgan Lewis

HM Revenue & Customs to Get Preferential Status as of 1 December 2020

Morgan Lewis on

With effect from 1 December 2020, the UK’s HM Revenue & Customs will be given preferential creditor status for certain taxes which a company has collected but failed to pay to HMRC on the date it enters insolvency. This was...more

Proskauer - Tax Talks

Extended tax liabilities for directors in insolvencies linked to tax avoidance

Proskauer - Tax Talks on

Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise...more

Morgan Lewis

UK’s Draft Finance Bill Proposes Preferential Status for HM Revenue & Customs

Morgan Lewis on

The UK government has published a draft Finance Bill 2020, which includes a provision that, if enacted, will give HM Revenue & Customs (HMRC) secondary preferential creditor status for certain taxes which a company has...more

Morrison & Foerster LLP

Return of Crown Preference at the Expense of Floating Chargeholders

Much controversy followed the British government’s announcement in 2018 that it intended to reintroduce a statutory priority for certain tax debts of companies subject to the UK insolvency regime. Following consultation by...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Proposes Preferential Status for Certain Taxes in Insolvencies

The U.K. government is proposing to reintroduce preferential status to certain taxes in U.K. insolvencies beginning 6 April 2020. If enacted: - certain taxes owed to HM Revenue & Customs (HMRC) would rank ahead of floating...more

K&L Gates LLP

Changing Priorities in UK Company Insolvencies

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In a consultation issued by the UK tax authority, HM Revenue & Customs (HMRC), on 26 February 2019, a change in the order of asset distribution in the insolvency of UK companies has been proposed. The amendments would newly...more

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