On August 12, 2026, in K Alain, L.L.L.P. v. Commissioner,[1] the U.S. Court of Appeals for the Fifth Circuit withdrew its taxpayer-friendly January 16, 2026 opinion in Sirius Solutions, L.L.L.P. v. Commissioner,[2] and replaced it with a decision that is ambiguous in its application but appears…

On 13 July 2026, HMRC published a consultation on simplifying the process for obtaining treaty relief from UK withholding tax on interest paid overseas.

The consultation considers whether UK payers should be able to apply treaty relief at source without first obtaining a formal direction from HMRC. If implemented, this…

The UK government has published draft legislation for a new Securities Transfer Tax (STT), which is expected to replace the existing stamp duty and stamp duty reserve tax (SDRT) regimes for transfers of securities.

The proposal is intended to modernise and simplify the UK’s stamp taxes on shares regime by…

The Supreme Court has handed down its judgment in HMRC v BlueCrest Capital Management (UK) LLP, dismissing BlueCrest’s appeal and providing important clarification on the application of the salaried members rules to investment management LLPs.

The decision is particularly significant for asset managers, hedge fund managers and other investment…

HMRC has published updated guidance on the revised share reorganisation anti-avoidance rules following the changes introduced by Finance Act 2026. The guidance provides welcome confirmation that standard private equity management rollover arrangements should continue to benefit from share-for-share exchange relief despite concerns raised by the widening of the anti-avoidance provisions.…

On May 5, 2026, the Internal Revenue Service (“IRS”) released Revenue Procedure 2026-21 (the “Rev. Proc.”), which reinstates a program under which taxpayers may request private letter rulings (“PLRs”) on “significant issues” arising in certain corporate transactions[1] without asking the IRS to rule on the entire integrated transaction.[2]…

On April 21, 2026, in Liberty Global, Inc. v. United States, the Tenth Circuit held that the economic substance doctrine was “relevant” and applied to deny Liberty Global, Inc. a $2.4 billion deduction and imposed a 40% penalty with respect to a transaction known as “Project Soy”. The Tenth…

The Court of Appeal has confirmed in HMRC v M R Currell Ltd that, prior to the introduction of the disguised remuneration rules, a genuine and repayable loan made via an employee benefit trust (EBT) is not taxable as employment income.

Although the decision relates to a pre-Part 7A regime…

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