DISTRIBUTION

Julie Howard

Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.

Mike Lane

Zoe Andrews

An FFT decision on unallowable purpose and a Supreme Court ruling on an EU law challenge are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).

Andrew Howard

Andrew Howard (Ropes & Gray) examines the decision that covers some fundamental questions of UK partnership tax.

Andrew Howard

Even by the standards of tax cases, the recent case of BlueCrest Capital Management Cayman Ltd & others v HMRC is a difficult read. However, it is worth persevering with, because HMRC has taken the opportunity to test out a number of theories on partnership taxation, with some fairly alarming results for taxpayers.

Ashley Greenbank

Ashley Greenbank (Macfarlanes) reviews the proposals on company distributions, which would amend the transactions in securities rules and introduce a new targeted anti-avoidance rule.

Jackie Wheaton

Question My client is a life tenant of a trust. The trustees hold 100% of the shares of a BVI company which has recently sold a major part of its business and now wishes to repurchase its own shares. The question has arisen as to whether the funds...

Jeanette Zaman

Emma Game

Jeanette Zaman and Emma Game (Slaughter and May) consider whether the conditions for demergers to qualify as exempt distributions are in need of an overhaul

David Jervis, Elspeth Van den Brande, Ben Jones

In this comprehensive, seven-page report – which can be downloaded as a PDF – David Jervis, Ben Jones and Elspeth Van den Brande provide a detailed review of the tax deductibility rules across various European jurisdictions.

Chris Morgan

The monthly review by Chris Morgan examines two important developments in the EU, and the contrasting approaches to tax reform taken by Argentina and Portugal.