By the end of this year, the European Commission will present its legislative proposals for EU banking structural reform. Once the proposals are implemented, EU banks will have to separate their “investment” business from...more
The European Council Legal Service has issued an opinion that seriously questions the legal validity of the European Commission’s proposals for a financial transaction tax (FTT). The opinion finds that the extraterritorial...more
The U.K. Treasury recently published its response to its January 2013 consultation on transposing the EU Alternative Investment Fund Managers Directive (AIFMD). A revised draft version of the Alternative Investment Fund...more
Following the announcement in Budget 2013, HM Revenue & Customs (HMRC) issued a consultation document on May 20, 2013 that focuses on two areas of partnership taxation where HMRC perceive “unintended inconsistencies”...more
In this article we consider some alternative approaches to the proposed U.K. status of “employee shareholders,” who receive capital gains tax-exempt shares in their employer (or its parent) in return for waiving certain...more
Summary -
In an eagerly awaited decision of the U.K. Supreme Court in the case of R (on the Application of Prudential plc and Another) v. Special Commissioner of Income Tax and Another, [2013] UKSC 1, legal advice...more