Tax Talks

The Proskauer Tax Blog

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Richard Miller


Richard Miller is a partner in the Tax Department and a member of the Private Funds, Private Equity Transactions and Mergers & Acquisitions Groups.

Richard provides advice on a full range of UK and international tax matters. His practice specifically focuses on all aspects of the private fund lifecycle.

Richard acts for private fund asset managers in structuring and raising investments funds, structuring carried interest and coinvestment arrangements, establishment and operation of fund management businesses, M&A and investment activity and finance transactions.

Richard also represents institutional investors in structuring and negotiation their private fund investment activity including primary and secondary investments and bespoke transactions.

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Upcoming changes to the company share options plan regime

Company share option plans (CSOP) and enterprise management incentives (EMI) are two statutory share option regimes that can be used to incentivise employees in a tax-efficient way. Broadly, where the relevant qualifying criteria have been met, both the CSOP and EMI schemes allow employees to acquire shares in their employer (or its group) for less … Continue Reading

BEPS: Update on Action 6 on Treaty Benefits

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

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