David M. Ward
Associate
David Ward is an associate in the Tax Department.
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The Upper Tribunal (UT) has upheld the decision of the First‑tier Tribunal (FTT) regarding the application of the UK’s salaried member rules (the Rules) to certain members of BlueCrest Capital Management (UK) LLP (BlueCrest), an asset manager engaged in the provision of hedge fund management services. We previously reported on the FTT decision in June … Continue Reading
The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset management limited liability partnership (LLP). BlueCrest is engaged in providing hedge fund investment management services. In … Continue Reading
HMRC has recently updated the guidance relating to the UK’s new qualifying asset holding company (QAHC) tax regime which was introduced from 1 April 2022. The new guidance clarifies HMRC’s approach to whether corporate lending vehicles used by credit funds should be treated as carrying on an investment activity or a trade in the context … Continue Reading
On 8 October 2021, the OECD released a further statement in relation to the BEPS 2.0 proposals, aimed at addressing taxation of the modern digital economy. This is the latest development in the attempts to more equally share the tax revenue relating to digital services that have led to some jurisdictions, including the UK, introducing … Continue Reading
Significant progress has been made in the efforts of the OECD to reach international consensus on the BEPS 2.0 proposals. Broadly, the proposals are aimed at addressing challenges relating to taxation of the modern digital economy. The 139 country OECD Inclusive Framework meeting concluded on 1 July 2021, with 130 countries and jurisdictions, representing in … Continue Reading
BlueCrest – the Upper Tribunal considers the salaried member rules
By Stephen Pevsner, David M. Ward and Jagmaan S. Bakshi on Posted in Executive Compensation, Tax, UK Tax
BlueCrest FTT Decision – Salaried Member Rules and Asset Managers
By Stephen Pevsner, Robert E. Gaut, Catherine Sear and David M. Ward on Posted in In the news, Tax Policy, UK Tax
HMRC Clarifies Application of QAHC Regime to Corporate Lending Vehicles
By Robert E. Gaut, Stephen Pevsner and David M. Ward on Posted in Corporate Taxation, UK Tax
A step closer to agreement on taxation of the digital world
130 countries join the OECD’s framework for international tax reform
By Robert E. Gaut and David M. Ward on Posted in In the news, International Taxation
