Tax

News

Blackrock

Simmons loses tax appeal over $13.5bn BlackRock deal

The world’s largest asset manager, BlackRock, has had its appeal for tax relief dismissed following a hearing against HM Revenue and Customs (HMRC) in March. The appeal concerned the complex structure that BlackRock, represented by Simmons & Simmons’ partner Heather Rowlands, had used to buy Barclays Global Investors (GBI) for $13.5bn in 2009. In the […]

Calculating maths

“A headache for management”: HMRC update could trigger fresh cash calls

A wave of cash calls could be triggered following guidance from HM Revenue & Customs on the tax status of fixed-share partners. Managing partners told The Lawyer that the new Salaried Members Rules Guidance, published just days before the Spring Budget, would cause “headaches” and “confusion” for firms already contending with basis period reforms. One […]

Pinsents’ City office head leaves for DLA Piper

Pinsent Masons’ head of its London office is leaving after four years to join DLA Piper’s London corporate crime and investigations (CCI) team. Before joining Pinsents at the beginning of 2020, Sackey spent almost 13 years at HMRC in senior positions including deputy director of offshore, corporate, and wealthy investigations, and deputy director of criminal […]

Freshfields former tax chief jailed for fraud

Freshfields Bruckhaus Deringer’s former global head of tax was sentenced to three and a half years in prison by a Frankfurt court on Tuesday. Ulf Johannemann, who had been a partner in the magic circle firm’s Frankfurt office, was found to have assisted the German arm of the Canadian Maple Bank in fraudulent trading over […]

AI robot

AI generates fake case law in tax case

A woman appearing before the First-Tier Tribunal (FTT) Tax Chamber sought to rely on case law fabricated by AI, a judge has ruled. In what may be a first for the UK, the appellant, who represented herself and was appealing a £3,000 penalty issued by HMRC, was found to have unknowingly referenced nine FTT cases […]

Analysis

Beyond the Bubble: Inside Brabners’ new strategy

North West: As revealed in The Lawyer on Tuesday, Brabners has kicked off a new three-year strategy. The last one certainly paid dividends, and newly-reelected managing partner Nik White was in ebullient spirits when he talked to Beyond the Bubble earlier this week. “It’s the power of 24,” he says cryptically, before explaining that “it […]

2024’s newest silks: Why we chose a career in law

A solicitor-turned-barrister and the Bar’s newest doctor KC; The Lawyer speaks to six of the Bar’s newest silks. The group was announced as KCs-in-waiting earlier this year, with 95 barristers in total getting the nod. Among the 95 were Crucible Law’s Clea Topolski – who having been called in 2014 – is the most junior of the set. […]

Featured Briefings

The taxation of non-Irish resident landlords – Revenue manual published

Under the Finance Act 2021, non-Irish resident corporate landlords are now subject to Irish corporation tax at the rate of 25% on rental income from Irish property. The change takes effect for accounting periods commencing on or after 1 January 2022, and results in an increase in the tax rate from 20% to 25% for non-resident corporate landlords.

Guide to annual tax on enveloped dwellings (ATED)

ATED is an annual tax payable by companies that own UK residential property valued in excess of £500,000. The ATED period runs from 1 April to 31 March in the following year. The filing deadline is 30 April (following the 1 April) in each year.

Taxing employee compensation — know your (stock) options

It’s common for start-up and growing businesses to allocate a percentage of the company’s equity to stock options. The options are used to attract and incentivize key employees who are given the opportunity to share in the growing value of the business.

Spring Budget Statement 2022: Tax

The Chancellor has pledged to cut the basic rate of income tax by the next general election in 2024. This announcement was not anticipated beforehand. Tax & estate planning Partner James Austen comments on this and the so-called “Tax Plan” outlined.

In this age of Russia sanctions, U.S. importers can’t ignore the risks of customs compliance

In response to Russia’s invasion of Ukraine, countries around the world – including historically neutral states like Switzerland – have imposed restrictive sanctions on doing business with Russia. Importers and exporters still reeling from global supply chain challenges brought on by the Covid-19 pandemic are especially hard hit by these sanctions, which target trade and trade finance, banking, and transport activities, among other areas.

The concept of fixed establishment for VAT purposes

The international taxation concept of fixed establishment plays an increasingly important role in connection with indirect taxes such as VAT. As the discussion on this concept gains prominence, particularly due to the magnitude of international trade, the need to develop this concept beyond direct taxation purposes is proving to be essential.

2022 Tax dispute resolution monthly update | session 5

With the Canada Revenue Agency deploying massive resources to crack down on perceived tax avoidance, it’s now more important than ever to stay up to date with new CRA policies, legislation and case law. Please join Gowling WLG’s Tax Dispute Resolution Group for their 30 minute interactive monthly tax dispute resolution (TDR) webinars, to keep up with current developments and learn practical insights on how to successfully resolve tax disputes with the CRA.