Tax Talks

The Proskauer Tax Blog

Stephen Pevsner

Stephen Pevsner

Partner

Stephen Pevsner is a tax partner and a member of the Corporate Department.

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 private equity sponsors and investors.

In addition to his wealth of transactional knowledge he also has substantive experience advising on the formation of private investment funds and the establishment of investment management and advisory limited partnerships.

According to Chambers UK, Stephen is a notable practitioner in the corporate tax field, praised for "his ability to master the intricacies of tax law and understand the commercial aspects of the deal".

Stephen is a member of the BVCA Tax Committee and is a regular speaker at conferences and contributor to publications such as the Tax Journal and Tolley's.

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Advisers’ fees non-deductible where management decisions made by parent company

The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and were charged on to its subsidiary were deductible as expenses of management of the subsidiary under section 1219 of … Continue Reading

IR35 extension to private sector – Finance Bill 2020 amendment on territorial scope

There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain employment status assessment and, depending on the circumstances, employment tax payment obligations from the worker’s … Continue Reading

COVID-19: DAC 6 reporting delayed

In light of COVID-19, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative co-operation in the field of taxation. Significantly, the proposal includes an extension to the time limit for reporting information under the new rules on … Continue Reading

COVID-19: interim measures on stamp duty announced by HMRC

In response to the COVID-19 crisis HMRC has updated its guidance on the process for getting documents stamped and paying the stamp duty, including that: Stock transfer forms should not be posted to the Stamp Office. Instead an electronic copy (which can be a scanned PDF) should be emailed to HMRC at stampdutymailbox@hmrc.gov.uk. The form … Continue Reading

COVID-19: HMRC Announces its Approach to Company Residence

There has been considerable discussion about the effect that the travel restrictions resulting from the COVID-19 pandemic might have on the tax residence of companies, particularly where directors are stuck in a different jurisdiction and cannot attend board meetings as they would in normal circumstances. On 7 April, HMRC updated its published guidance to discuss … Continue Reading

COVID-19: UK Tax Residence for Companies and Individuals

Introduction In these testing times the ramifications of COVID-19 continue to be felt in every area of personal and corporate life. With lockdowns announced around the world, including in the UK on 23 March 2020, travel has been severely curtailed and business practices are having to change accordingly. Below we discuss what this means for … Continue Reading

COVID-19: UK Chancellor announces measures to support the self-employed

Earlier this evening (26 March 2020) the UK Chancellor announced the new Self-Employed Income Support Scheme to help the self-employed face the economic hardship wrought by the COVID-19 pandemic. Below are the key points: The scheme will provide direct cash grants of 80 per cent of individuals’ taxable profits (based on average monthly trading profit … Continue Reading

Coronavirus: UK Chancellor announces unprecedented measures to support the British economy

Earlier this evening the UK Chancellor announced an economic intervention which is “unprecedented in the history of the British state” with measures to support the United Kingdom economy in the midst of COVID-19. Below are the key measures he announced for businesses: The government is setting up a Coronavirus Job Retention Scheme. The scheme will … Continue Reading

Latest on Abolition of Entrepreneurs’ Relief

There has been much talk recently about “review and reform” (or abolition) of entrepreneurs’ relief. This seems to have moved a step closer this week with Boris Johnson stating that the Treasury are “fulminating” against it on the basis that it made “staggeringly rich” people “even more staggeringly rich”. The debate about this was kicked … Continue Reading

Simplification of UK Partnership Tax Reporting for Investment Fund Partnerships

In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment fund partnerships. The changes covered a number of areas, including requiring a UK partnership that had partnerships amongst its partners … Continue Reading

Extended tax liabilities for directors in insolvencies linked to tax avoidance

Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise from avoidance, evasion or repeated insolvency and non-payment of tax debts or tax-related penalties of the company. The legislation is targeted at individuals … Continue Reading

Change to IR35 tax obligations from April 2020 for medium- and large-sized companies

New rules to be introduced from April 2020 will make certain companies who engage workers through intermediaries (the “client”) subject to: assessing whether the workers should be treated as employees of the company; and operating employment tax (PAYE and NICs) in respect of payments made to the workers or their intermediary. Currently these obligations rest … Continue Reading

UK Tax Round Up

UK General Tax Developments HMRC updates guidance on what constitutes “ordinary share capital” Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this month, HMRC has updated its guidance on what constitutes “ordinary share capital” for the purposes of most tax provisions using that term. As well as … Continue Reading

Are fixed rate preference shares “ordinary share capital” for entrepreneurs’ relief – more or less certainty?

There has been another development on the tricky but important subject of whether the rights attaching to preference shares mean that they are or are not ordinary shares for entrepreneurs’ relief (and other tax) purposes. Recent cases have shown that share with no right to a dividend are ordinary shares. HMRC has published its view … Continue Reading

UK Budget – Some Key Changes

The UK Budget took place on 29th October. The Chancellor, Philip Hammond, took the opportunity to make a series of targeted changes to the UK’s tax system, some of which had already been announced, but several of which were new and surprising. We have summarized here of the most eye-catching changes that will be of … Continue Reading
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