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CMS Cameron McKenna Nabarro Olswang LLP | United Kingdom | 16 Nov 2018

Fortune favours the...Crown

The Chancellor announced in his budget that the Crown is to be re-instated as a preferential creditor in insolvency, reversing the changes brought in


DLA Piper | United Kingdom | 19 May 2014

Pensions news (UK) - April 2014

When far-reaching DC reform due to come into force in April 2015 was announced in the Budget, some schemes received requests from members who had


Fredrikson & Byron PA | USA | 11 Oct 2011

SSA Inspector General finds anomalies in H-1B workers’ use of social security numbers

The Social Security Administration’s Office of the Inspector General (OIG) released a report in September on H-1B workers’ use of Social Security Numbers (SSNs) that could result in more close monitoring of status violations by H-1B workers and potential liability for H-1B employers.


Squire Patton Boggs | USA, United Kingdom | 9 Sep 2011

Double taxation relief: UK relief for tax paid by a Delaware LLC

The anonymised tribunal case of Swift last year has now been appealed to the Upper Tribunal and is now known as Anson v HMRC FTC392010.


Herbert Smith Freehills LLP | United Kingdom | 19 Aug 2011

Corfield: adequate disclosure to prevent discovery assessments

In Corfield, Corfield and Charlton v HMRC, the First-tier Tribunal decided that "discovery" assessments issued by HMRC were not valid because the taxpayers had made adequate disclosure in their returns.


Squire Patton Boggs | United Kingdom | 3 May 2011

EBTs: inheritance tax and income tax

HMRC have issued a new brief (1811) setting out their view of the inheritance tax and income tax implications of contributions to an EBT by a close company.


Squire Patton Boggs | United Kingdom | 28 Feb 2011

Transfers of Assets Abroad

The Transfers of Assets Abroad legislation in and around section 720 Income Tax Act 2007 (probably still better known under its previous incarnation as Section 739 TA 1988) is exceptionally complex, being designed to frustrate plans to avoid income tax by arranging for income to be paid abroad.


Bird & Bird LLP | United Kingdom | 22 Feb 2011

Disguised remuneration

On 9 December 2010 HMRC published controversial draft regulations designed to prevent so called "disguised remuneration" (usually in the form of bonuses structured as loans made to employees via off-shore trusts).


Squire Patton Boggs | United Kingdom | 5 Jan 2011

Employee expenses

I will not dwell on the case of Peter Gamble v HMRC TC 815 in which Mr Gamble made a claim for certain expenses to be deducted from his employment income.


Cadwalader Wickersham & Taft LLP | United Kingdom | 27 Aug 2010

Group mismatch schemes: proposed legislation and open meeting on 23 July 2010

In the Budget held on 24 March 2010, HMRC published a discussion document regarding the proposed introduction of a generic or principles-based rule to respond to certain arrangements termed "group mismatch schemes".

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