We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search

Clear all

Refine your search

Content type

Tags

Author

15 results found

Article

Fried Frank Harris Shriver & Jacobson LLP | United Kingdom | 21 Oct 2013

Proposed changes to UK tax treatment of partnerships and LLPs: further update

In its policy paper entitled "Partnerships Review: Proposed NICs changes for (i) Disguised Employment and (ii) Profit Deferral under Alternative

Article

Fried Frank Harris Shriver & Jacobson LLP | United Kingdom | 24 May 2013

Proposed changes to UK tax treatment of partnerships and LLPs

HMRC published this week a consultation paper entitled "Review of tax rules on partnerships: disguised employment and profit and loss allocation

Article

Fried Frank Harris Shriver & Jacobson LLP | United Kingdom | 8 Oct 2012

Proposed amendments to UK withholding tax rules on interest payments

On 2 October 2012, HM Revenue & Customs (HMRC) published a summary of industry responses to their earlier consultation paper of 27 March 2012.

Article

Fried Frank Harris Shriver & Jacobson LLP | United Kingdom | 20 Jun 2012

Beneficial ownership under tax agreements: further UK revenue guidance published

There have been several cases in Europe and beyond over the past few years concerning the concept of beneficial ownership under double tax agreements (“DTAs”).

Article

Fried Frank Harris Shriver & Jacobson LLP | USA | 2 Apr 2012

Proposed amendments to UK withholding tax rules on interest payments rules on interest payments

HM Revenue & Customs published on 27th March 2012 a consultation paper with proposals to amend certain income tax rules affecting interest payments.

Article

Fried Frank Harris Shriver & Jacobson LLP | USA, United Kingdom | 8 Aug 2011

Delaware LLCs entity status for UK tax purposes: update

The judgment of Mr Justice Mann in the Upper Tier Tribunal in Anson v Revenue and Customs Commissioners (FTC392010) was published on 5 August 2011.

Article

Fried Frank Harris Shriver & Jacobson LLP | United Kingdom | 3 Jun 2010

New “Double Tax Treaty Passport Scheme” for lenders to the UK launched

The full details of the UK's new Double Tax Treaty Passport Scheme ("Scheme") have now been announced by HM Revenue & Customs ("HMRC").

Article

Fried Frank Harris Shriver & Jacobson LLP | USA, United Kingdom | 18 Mar 2010

Delaware LLCs entity status for UK tax purposes

A recent decision of the UK's First-Tier Tribunal creates uncertainty in relation to the commonly accepted UK tax treatment of interests in Delaware Limited Liability Companies (Mr Swift v Commissioners, TC00399).

Article

Fried Frank Harris Shriver & Jacobson LLP | United Kingdom | 16 Mar 2010

UK bank payroll tax further clarifications and exclusions issued

Following our previous Fried Frank memoranda on the topic of the UK's bank payroll tax (11th December and 21st December 2009), the UK tax authority, HM Revenue & Customs ("HMRC"), has on 12th March 2010 issued a series of further clarifications and limitations on the scope of the tax.

Article

Fried Frank Harris Shriver & Jacobson LLP | USA | 27 Jan 2010

UK CFC reforms - new discussion document published

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).

Previous page 1 2