One minute with Stephen Hoyle, Head of Tax, DLA Piper
Name a recent piece of work of which you are most proud?
It is a transaction; the acquisition of HSBC Rail by an infrastructure consortium in late 2010. It was complex with some very stimulating tax points. Indeed so much of the taxation arising around leasing companies can be challenging.
Where do you stand on the introduction of a GAAR?
I have strong views on this. Graham Aaronson QC is the leading tax advocate of his generation but there is a trap that he has to avoid – a trap into which barristers can fall – which is thinking that a problem can be solved by a turn of phrase. A ‘turn of phrase’ can work well in an opinion or in argument but be much less successful in a judgment. We...
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One minute with Stephen Hoyle, Head of Tax, DLA Piper
Name a recent piece of work of which you are most proud?
It is a transaction; the acquisition of HSBC Rail by an infrastructure consortium in late 2010. It was complex with some very stimulating tax points. Indeed so much of the taxation arising around leasing companies can be challenging.
Where do you stand on the introduction of a GAAR?
I have strong views on this. Graham Aaronson QC is the leading tax advocate of his generation but there is a trap that he has to avoid – a trap into which barristers can fall – which is thinking that a problem can be solved by a turn of phrase. A ‘turn of phrase’ can work well in an opinion or in argument but be much less successful in a judgment. We...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")