News & Analysis as of September 1, 2025

Dividends

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

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

Cadwalader, Wickersham & Taft LLP on 7/23/2025

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

Extracting Value

Cadwalader, Wickersham & Taft LLP on 10/23/2024

Establishing the timing of a corporate dividend can be an important feature in a number of transactions where value is being extracted from a company. In the recent case of HMRC v Gould [2024] UKUT 00285 (TCC) (“Gould”), the...more

UK Tax Round Up - November 2022

Proskauer Rose LLP on 12/6/2022

Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more

Focus on Tax Controversy - Summer 2015

McDermott Will & Emery on 7/15/2015

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

Tax Measures in the UK 2015 Summer Budget

Morgan Lewis on 7/10/2015

The new tax announcements are designed to improve productivity and correct imbalances in the tax system. On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

UK Supreme Court case of Anson v. HMRC [2015] UKSC 44

Proskauer Rose LLP on 7/9/2015

Delaware LLC held to be UK tax transparent - The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC as transparent for UK tax...more

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