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Results:1-10 of 126

High Court of Australia upholds imputation benefits of hybrid instrument (Mills v Commissioner of Taxation)
  • Russell McVeagh
  • New Zealand, Australia
  • November 19 2012

The High Court of Australia has unanimously held that the provision of franking credits as part of the return on a hybrid instrument was an "incidental purpose" to that of the overall purpose of raising capital for the issuing banking group.


UBS AG and DB Group Services v HMRC: tax avoidance scheme succeeds at the Upper Tribunal
  • RPC
  • United Kingdom
  • November 2 2012

The eagerly awaited decision of the Upper Tribunal (UT) in the case of UBS AG and DB Group Services (UK) Limited v HMRC2 has now been released.


Tax avoidance scheme succeeds at the Upper Tribunal
  • RPC
  • United Kingdom
  • October 5 2012

The eagerly awaited decision of the Upper Tribunal (‘UT’) in the case of UBS AG and DB Group Services (UK) Limited v HMRC 2012 UKUT 320 (TCC) has now been released.


Countdown to March 18, 2012: are you ready?
  • Morrison & Foerster LLP
  • USA
  • October 21 2011

Despite this summer’s extension of the FATCA withholding rules (scheduled to be phased-in over 2014 and 2015), FATCA’s next effective date (March 18, 2012) will continue to greatly impact global financial transactions.


IRS issues new timeline for implementation of FATCA
  • Lowenstein Sandler LLP
  • USA
  • August 18 2011

The IRS has issued a new timeline for implementing the onerous requirements imposed on foreign financial institutions (including foreign hedge funds and private equity funds) by the Foreign Account Tax Compliance Act (“FATCA”).


Employee bonus schemes involving forfeitable shares - Part 2
  • CMS
  • United Kingdom
  • February 17 2011

HM Revenue & Customs ("HMRC") has won yet another case on the tax treatment of an annual bonus scheme involving shares, which was used before 2004 since when legislation has been significantly tightened so as effectively to block further use of these schemes.


The Government makes key announcements on anti-avoidance measures
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 7 2010

Yesterday, the Government launched a 'study programme' to establish whether an effective General Anti-Avoidance Rule (GAAR) could be developed to form part of the UK tax system.


ISDA protocol addresses new withholding rules for dividend equivalent payments
  • Eversheds Sutherland (US) LLP
  • USA
  • September 1 2010

On August 23, 2010, the International Swaps and Derivatives Association (ISDA) announced a new Protocol intended to address new U.S. withholding tax rules for certain notional principal contract payments. Under


Loan relationships and derivative contracts: derecognition of income
  • Cadwalader Wickersham & Taft LLP
  • United Kingdom
  • August 27 2010

The summer has seen a number of examples of HMRC acting to limit tax avoidance involving accounting (and, therefore, tax) derecognition of credits arising on a company's loan relationships and derivative contracts.


United Kingdom budget 2010: securing the recovery
  • Morgan Lewis
  • United Kingdom
  • March 25 2010

The 2010 UK Government budget was handed down on 24 March.