Proskauer Rose LLP | United Kingdom, USA | 3 Jan 2024
On 6 December, HMRC updated the section in its International Manual discussing the UK tax characterisation of overseas entities, and of Delaware (and…
Carey Olsen | United Kingdom, USA | 20 Dec 2018
Often described as a hybrid between a company limited by shares (LTD) and a partnership, limited liability companies (LLCs) are widely regarded as…
Ropes & Gray LLP | China, United Kingdom, USA | 21 Apr 2017
On July 8, 2016, the Delaware Court of Chancery released its post-trial opinion in an appraisal action that arose from the sale of DFC Global…
Proskauer Rose LLP | European Union, Hong Kong, Ireland, etc. | 15 Nov 2016
On March 10, 2016, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a…
Latham & Watkins LLP | United Kingdom, USA | 19 Nov 2015
Business as usual for UK taxpayers following Supreme Court decision in Anson v HMRC? HM Revenue and Customs (HMRC) has published its response to the…
Latham & Watkins LLP | United Kingdom, USA | 14 Aug 2015
On 1 July 2015, the UK Supreme Court handed down a long-awaited ruling in the case of Anson v Commissioners for Her Majesty’s Revenue & Customs [2015]…
Shearman & Sterling LLP | United Kingdom, USA | 6 Jul 2015
The UK Supreme Court delivered an unexpected final judgment on 1 July 2015 in the long-running case of Anson v Commissioners for Her Majesty's Revenue…
Duane Morris LLP | United Kingdom, USA | 2 Jul 2015
In an unexpected decision, the United Kingdom Supreme Court has held in Anson v Commissioners for Her Majesty’s Revenue & Customs [2015] UKSC 144 that…
Sullivan & Cromwell LLP | United Kingdom, USA | 28 Feb 2013
Whether a non-UK entity such as a Delaware limited liability company (“LLC”) is treated as transparent or opaque for UK tax purposes can make a…
Bryan Cave Leighton Paisner (Bryan Cave) | United Kingdom, USA | 30 Mar 2012
For the purposes of deciding how a member is to be taxed on the income they derive from their interest in an entity, HM Revenue & Customs (“HMRC”), classifies various foreign entities as either fiscally “transparent” or “opaque.”