Navigating Russia Sanctions
Private Equity and Delaware Law – Part One
Life sciences companies (particularly early stage companies) may be attracted to an LLC holding company structure as an alternative to a typical C corporation structure to maximize both the purchase price paid by a future...more
U.S. venture capitalists investing at the early stages (Seed and Series A) in a UK (or other non-U.S.) company often require that the company “flips” its corporate structure and establishes a U.S. (most commonly Delaware)...more
On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more
Real estate business owners face unique challenges that many business owners in other industries do not experience. The real estate market climbs and falls, contractor fees and material costs rise with inflation, and high...more
“Equity has no place here,” held the Supreme Court of Canada in its 8-1 decision in Canada (Attorney General) v Collins Family Trust (Collins), 2022 SCC 26, on June 17. Reversing the decisions of the British Columbia courts...more
Introduction The UK’s new Qualifying Asset Holding Company Regime (the “QAHC Regime”) comes into effect on 1 April 2022. The main objective of the regime is to make the UK a more desirable jurisdiction from which funds (which...more
The United Kingdom ("UK") Qualifying Asset Holding Company ("QAHC") regime (at Schedule 2 to Finance Act 2022) comes into force on 1 April 2022. The HM Revenue & Customs ("HMRC") policy paper dated 27 October 2021 states:...more
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
As we draw close to the end of the year, we take a moment to revisit some of the taxation changes announced in the Autumn budget, with some of these being implemented in the upcoming tax year in April 2022. ...more
This is likely to be a key reflection when considering the details issued in July about the new UK holding company regime for “qualifying asset holding companies” (QAHCs). The new regime is intended to make the UK more...more
On 20 July 2021, the UK government published further details of, and draft legislation for, a new elective tax regime for alternative fund structures. Although certain aspects have yet to be clarified, the proposals have...more
The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more
COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more