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United Kingdom Tax Liability Capital Gains

Dechert LLP

Labour Budget 2024: Reforms to the Taxation of Carried Interest

Dechert LLP on

The Chancellor of the Exchequer, Rachel Reeves MP, presented her first Budget to Parliament on 30 October 2024. In it, she announced both tax rate increases and also proposals which would fundamentally change the tax...more

Goodwin

A Token of Appreciation: Cryptoassets and Employee Incentives - a UK Tax Primer

Goodwin on

Businesses in the blockchain and cryptoasset space are increasingly looking to utilise digital currency and other cryptoassets as an alternative to or alongside other, more traditional employee incentive arrangements, such as...more

Cadwalader, Wickersham & Taft LLP

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

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

Cadwalader, Wickersham & Taft LLP

Court of Justice Rules on UK Group Asset Transfer Rules

The UK tax legislation imposes an “exit tax charge” on the unrealised capital gains of a company which migrates from the UK. The exit of a taxpayer (or their assets) is generally the last point in which a taxing jurisdiction...more

King & Spalding

Capital Gains Tax (CGT) payable by non-UK resident investors on direct and indirect disposals of UK commercial real estate

King & Spalding on

Non-UK resident investors (Investor) usually acquire UK commercial real estate (UK Property) through non-UK resident companies, for example Jersey limited liability companies. A typical holding structure put in place by an...more

Morrison & Foerster LLP

European M+A News, Winter 2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

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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