Bøger af Pete Miller

Taxation of Company Reorganisations is one of the leading commentaries in the UK on dealing with all aspects of reorganising of restructuring a company.Readers will benefit from the practical expertise of the authors, led by Pete Miller of Jerroms Miller and George Hardy and Fehzaan Ismail both of Ernst and Young, gained in the course of over 50 years of practical experience dealing with corporate tax transactions for clients all sizes.The book contains expert guidance on a variety of topics, from the reduction of capital rules, and interaction with substantial shareholding exemption, to qualifying corporate bonds (QCBs), reconstruction reliefs, and UK and cross-border mergers. The commentary includes analysis of key cases and is supported by a series of easy to follow diagrams and flowcharts to support key points. The new edition brings the commentary up to date with recent Finance Acts including new provisions relating to share exchanges involving non-UK incorporated close companies introduced in Finance (No. 2) Act 2023; and relevant new guidance from HMRC including the unallowable purpose rules. A number of important new cases are also discussed, including the following: - Euromoney Institutional Investor PLC (FT): Anti-avoidance on exchange of shares - Gallaher (various including UT and CJEU): intra-group transactions and EU law - Kavanagh (FT): Holding shares on trust - Blackrock (UTT): deductability of interest on a intra-group loan - Oxford Instruments (FTT), and Kwik Fit Group Ltd (UT): unallowable purpose test - Altrad Services (UT): disclosed avoidance scheme - M Group Holdings (FTT): substantial shareholding exemptionsThis title is included in both the Gold and Platinum Online Tax Services.

Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work.This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018- The introduction of LBTT in Scotland and LTT in Wales- Stamp duty changes proposed for FA 2020- Enhanced material on the taxation of goodwill and loan relationships on a reorganisationCases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992)- Hancock [2019] 1 WLR 3409 (Supreme Court decision)- Trigg [2018] EWCA Civ 17 (Court of Appeal decision)