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UK CFC reforms - new discussion document published
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • January 27 2010

A further discussion document relating to the proposed reforms of the UK’s controlled foreign companies regime has now been published, as envisaged by the HM Treasury and HM Revenue & Customs representatives at the joint meeting with stakeholders held on 9th November last year (see "Update on the Reform of the UK’s CFC Tax Regime", 10th November).

Tax Chamber decision in Laerstate is a cautionary tale of a failure to maintain non-UK tax residence
  • Fried Frank Harris Shriver & Jacobson LLP
  • United Kingdom
  • September 16 2009

A recent decision of the Tax Chamber of the UK’s newly constituted First-Tier Tribunal, Laerstate BV v Commissioners for HMRC, provides a reminder that the maintenance of non-UK corporate residence requires careful management, particularly when influential personnel are active in the UK.

Keith Featherstone
  • Fried Frank Harris Shriver & Jacobson LLP