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Foreign Corporations HMRC Income Taxes

Cadwalader, Wickersham & Taft LLP

Beard v HMRC: Capital Dividends. A Triumph of Form Over Substance?

Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more

Proskauer Rose LLP

UK Tax Round Up - December 2018

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UK Developments - Taxpayer succeeds in judicial review case against HMRC - On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK)...more

Proskauer Rose LLP

UK Tax Round Up - April 2018

Proskauer Rose LLP on

General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more

Proskauer Rose LLP

UK Tax Round Up - February 2018

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Case law developments - Settlement payment not deductible as an expense of a trade (Vaines v HMRC) - Mr. Vaines was a solicitor. In the 2007/08 tax year he paid a settlement amount to a third party that had made a...more

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