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Posts Tagged ‘International tax’

Manufactured Overseas Dividends

The Government has taken immediate steps to clarify the tax treatment of Manufactured Overseas Dividends (MOD) by publishing draft legislation to be incorporated within the 2012 Finance Bill. The legislation will take effect for MOD paid on or after the date of the announcement, 15 September 2011, and is estimated to increase tax receipts by…

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UK double taxation treaties and Delaware LLCs

The upper tax tribunal has released its decision in respect of HMRC v George Anson, a case which involved the interpretation of the UK/US double taxation agreement in respect of Delaware LLCs. By way of background it is helpful to understand the following: • A transparent entity is one in which the member is entitled…

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