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ANALYSIS

Cutting edge analysis on tax issues.

The proposed IHT reforms seem to attack the farmers they should protect and protect the people they should tax, writes Stuart Maggs (Howes Percival).
May Smith and Emily Szasz (Freshfields) examine some of the key tax considerations that arise in relation to the transfer of assets into a continuation fund.
The UK is likely to become more attractive in the short term for overseas employees but less attractive in the medium to long term, Claire Murray and Nisus Larsen (Alvarez & Marsal) explain.
Jenny Doak and Akash Mehta (Weil, Gotshal & Manges) discuss some key considerations for M&A transactions.
Shayaan Zaraq Bari and Nicholas Gardner (Ashurst) explain how combining W&I insurance with other tools may help bridge any gaps in tax risk coverage and maximise protection for buyers.
In this month’s review, Gary Barnett (Simmons & Simmons) reviews the agreement on ViDA, the consultation responses on CBAM in the UK and the impact of an Upper Tribunal decision on supplies by public bodies.
Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).
The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).
John Shallcross (Blake Morgan) sets out what can be learnt from a recent decision where the FTT held HMRC could refuse to give effect to an overpayment relief claim for SDLT involving MDR for mixed property.
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