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United Kingdom HMRC Dividends

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

Cadwalader, Wickersham & Taft LLP

Extracting Value

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

Proskauer Rose LLP

UK Tax Round Up - November 2022

Proskauer Rose LLP on

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

Proskauer - Tax Talks

Zero Dividend Shares are Ordinary Share Capital

Proskauer - Tax Talks on

The Upper Tribunal (Tax and Chancery Chamber), the UK’s second level tax appeal court, have just published their judgement in the McQuillan case, which considered whether shares with no right to dividends or any other profits...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

McDermott Will & Emery

Focus on Tax Controversy - Summer 2015

McDermott Will & Emery on

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

Morgan Lewis

Tax Measures in the UK 2015 Summer Budget

Morgan Lewis on

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

Proskauer Rose LLP

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

Proskauer Rose LLP on

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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