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Tax Deductions Acquisition Agreements Tax Liability

Cadwalader, Wickersham & Taft LLP

Complex Borrowing and Group Structures

The Court of Appeal’s (“CA”) ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC (“BlackRock”) considered the deductibility of interest on a $4 billion intra-group loan put in place as part of the funding...more

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