Robert E. Gaut
Partner
Robert Gaut is a tax partner and head of our UK tax practice in London.
He has represented many of the world’s preeminent multinational corporations, sovereign wealth funds, investment banks and private equity funds on a full range of UK and international tax strategies relating to inbound and outbound transactions, capital markets offerings, establishment of investment funds and financing matters.
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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 are or are not “ordinary share capital” (OSC) for UK tax purposes. There are a number of UK tax … Continue Reading
Background As mentioned in our July 2017 edition of UK Tax Round Up, the UK has enacted a new corporate criminal offence of failing to prevent the facilitation of tax evasion. The law comes into effect on 30th September 2017, and businesses should ensure that they have considered its impact before then. A risk assessment … Continue Reading
The summer break means that we are still waiting for the new Parliament’s drafts of the Customs, National Insurance Contributions and Finance (No 2) Bills discussed in the July 2017 edition although the timeline for the Finance (No 2) Bill has now been clarified. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
It has been another relatively quiet month from a tax perspective as we continue to wait for the Summer Finance Bill, the first Finance Bill of the new Parliament, to be published. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Following the UK general election on 8 June 2017, at which Theresa May’s Conservative party won the largest number of seats but lost its overall majority, the Queen’s Speech setting out the now minority Conservative government’s legislative programme for the next two years was delivered on 21 June 2017 at the state opening of Parliament. … Continue Reading
This month has been quiet from a tax perspective as a number of significant tax measures planned for inclusion in the first Finance Act 2017 were put on hold until after the general election. We will report on their progress in future editions. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
The previous month has been dominated by politics, with an announcement of a snap general election leading to postponement of many proposals in draft legislation. This month’s edition of the UK Tax Round Up discusses how certain provisions of the draft legislation could be impacted by the election, among other issues.… Continue Reading
In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”). One area that the OECD has itself acknowledged requires further consideration is in relation … Continue Reading
The Proskauer Tax Department is pleased to announce that Stephen Pevsner has joined as a partner in our London office. Stephen’s practice focuses on UK and international M&A and private equity transactions, corporate reorganizations, and new business formations. Offering a broad range of corporate tax strategy experience, his clients include global corporations, investment banks, and … Continue Reading
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on November 24, 2016. The Convention is the latest in an ongoing series of releases related to the OECD/G20 Project addressing Base Erosion and Profit Shifting … Continue Reading
Robert Gaut, the head of our UK tax practice and a partner in the London office of Proskauer, spoke on 20th September on a panel at the International Bar Association’s annual conference in Washington, D.C. The panel was entitled “Practical Issues in Entity Classification and Claiming Tax Treaty Benefits for Transparent Entities”. Along with co-panelists … Continue Reading
Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities will take place next year, with all CRS jurisdictions exchanging information by 2018. And we are now starting to see how tax authorities expect this … Continue Reading
We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will be adopted in the next Council meeting, which is scheduled for 12th July. The Council had reached … Continue Reading
Country-by-country reporting (“CBCR”) is one of the OECD BEPS deliverables (under Action 13). It is expected to be a significant tool used by tax authorities’ auditors in evaluating a multinational group’s transfer pricing policies. CBCR will present significant challenges to multinationals groups’ internal tax departments, as the tax departments must reconcile public financial reports to … Continue Reading
The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our attention. Capital gains tax (CGT) rates for individuals have been reduced from 28% to 18% (for higher and … Continue Reading
On 28 January 2016, the European Commission published a draft Anti Tax Avoidance Package in order to ensure increased tax transparency and effective taxation within, and outside of, the EU. The package includes a proposed Directive on tax avoidance practices (discussed further below), amendments to the Directive on automatic information exchange in order to gather … Continue Reading
With effect from 8th July, 2015, UK resident investment management executives will pay capital gains tax on all their carried interest returns from investment funds (with the rate currently set at 28% for higher and additional rate taxpayers). The overall rate may in many cases be higher, since items of income such as interest and … Continue Reading
Zero Dividend Shares are Ordinary Share Capital
By Stephen Pevsner, Robert E. Gaut and Catherine Sear on Posted in UK Tax
Failure to Prevent the Facilitation of Tax Evasion: New United Kingdom Corporate Criminal Offence
By Robert E. Gaut, Stephen Pevsner and Catherine Sear on Posted in Compliance, UK Tax
UK Tax Round Up: August 2017
By Robert E. Gaut, Stephen Pevsner and Catherine Sear on Posted in UK Tax
UK Tax Round Up: July 2017
By Robert E. Gaut, Stephen Pevsner and Catherine Sear on Posted in UK Tax
Conservative Legislative Agenda Set Out in Queen’s Speech
By Robert E. Gaut and Richard Miller on Posted in UK Tax
UK Tax Round Up: June 2017
By Robert E. Gaut, Stephen Pevsner and Catherine Sear on Posted in UK Tax
UK Tax Round Up: May 2017
By Robert E. Gaut, Stephen Pevsner and Catherine Sear on Posted in UK Tax
BEPS: Update on Action 6 on Treaty Benefits
By Robert E. Gaut and Richard Miller on Posted in Base Erosion and Profit Shifting, International Taxation
Proskauer Bolsters International Tax Practice with Addition of Stephen Pevsner in London
By Robert E. Gaut on Posted in Proskauer Tax Department Announcements
BEPS: OECD Releases Multilateral Tax Treaty Convention
Key Takeaways from IBA Annual Conference Panel
By Robert E. Gaut on Posted in International Taxation
Proposed New UK Penalties Regime Precipitated by CRS
By Robert E. Gaut, Catherine Sear and Gregory Branagan on Posted in UK Tax
EU Council Agrees on Final Anti Tax Avoidance Directive
By Robert E. Gaut on Posted in Base Erosion and Profit Shifting
New Public Country-by-Country Reporting of Financial Information Proposed by European Commission
By Robert E. Gaut on Posted in Base Erosion and Profit Shifting, International Taxation
Tax Announcements in the UK’s Budget 2016
By Robert E. Gaut, Catherine Sear and Gregory Branagan on Posted in UK Tax
European Commission Publishes Anti Tax Avoidance Package
By Daniella Abel and Robert E. Gaut on Posted in Base Erosion and Profit Shifting
United Kingdom Makes Significant Changes to the Tax on Carried Interest for Investment Management Executives
By Robert E. Gaut on Posted in UK Tax
