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Appeals Court rules against the IRS and affirms refund for National Westminster Bank PLC

Alston & Bird LLP
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United Kingdom, USA
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February 15 2008

On January 15, 2008, the U.S. Court of Appeals for the Federal Circuit affirmed a decision of the Court of Federal Claims that National Westminster Bank PLC (“NatWest”) was entitled to a refund of $65.7 million with interest for 1981-87

Important implications for group relief claims (non-UK parents)

Dorsey & Whitney LLP
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United Kingdom, USA
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November 17 2009

If applying the M&S case, group relief is permissible between the UK and non-UK EU subsidiaries of a common UK parent, we argue the same must apply if the common parent is resident outside the UK (e.g. in the Netherlands or the USA

A Swift analysis

Jones Day
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United Kingdom, USA
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May 31 2010

The First Tier Tribunal's finding in the Swift case that a Delaware limited liability company was not an opaque vehicle for UK tax purposes has caused a stir in the international tax structuring arena

Success for the taxpayer in pre-FA 2000 group relief claims

Dorsey & Whitney LLP
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United Kingdom, USA
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June 2 2010

On 1 April 2010, the First-tier Tribunal (FTT) found in favour of the taxpayer in FCE Bank plc v Commissioners for HMRC 2010 UKFTT 136 (TC

US citizens beware your tax obligations

Kingsley Napley
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United Kingdom, USA
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August 11 2010

In March of this year President Obama signed into law the Hiring Incentives to Restore Employment (Hire) Act which introduced new registration and US withholding tax requirements on all financial institutions worldwide

The Emergency UK Budget 2010: key taxation aspects

Cadwalader Wickersham & Taft LLP
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United Kingdom, USA
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June 23 2010

On Tuesday 22 June 2010, the 'Emergency' Budget of the UK's new Coalition Government was delivered by the Chancellor of the Exchequer

USUK dual qualified charities

Bircham Dyson Bell
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United Kingdom, USA
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November 26 2010

US citizens (and other individuals subject to US income tax) who are resident in the UK, may be subject to tax in either the US or the UK when they make contributions to charity unless the charity is dual qualified

Tax court rules that UK windfall tax is creditable in the United States

Caplin & Drysdale
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United Kingdom, USA
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September 17 2010

In PPL Corp v Commissioner(1) the Tax Court recently held that the UK 'windfall tax'(2) is creditable for US tax purposes

UK holding companies: not yet working?

Chadbourne & Parke LLP
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United Kingdom, USA
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November 12 2010

"Good for business, good for the UK" is a theme of much UK government rhetoric that has been reflected in a series of "good for business" tax changes

Recent developments for the Third Quarter 2010

Baker & McKenzie
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Canada, China, Estonia, European Union, France, Ireland, Japan, Mexico, Portugal, Russia, Turkey, United Kingdom, USA, Venezuela, Vietnam
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December 16 2010

This letter is from the Global Equity Services ("GES") group in San Francisco, Chicago and New York

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Search results

Appeals Court rules against the IRS and affirms refund for National Westminster Bank PLC

Important implications for group relief claims (non-UK parents)

A Swift analysis

Success for the taxpayer in pre-FA 2000 group relief claims

US citizens beware your tax obligations

The Emergency UK Budget 2010: key taxation aspects

USUK dual qualified charities

Tax court rules that UK windfall tax is creditable in the United States

UK holding companies: not yet working?

Recent developments for the Third Quarter 2010

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