Blog Archives

What Happens If You Run Your US Business from the UK?

In this episode of US-UK Tax Talk, Aidan Grant is joined by Alex Straight, Partner in the US team at Blick Rothenberg, to discuss the tax and practical issues that arise when entrepreneurs and business owners run a business cross-border …

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Private Equity Explained: From Deal Structure to Exit

In this episode of US-UK Tax Talk, host Aidan Grant is joined by his Collyer Bristow colleague Ragavan Arunachalam, Partner and Head of Private Equity, for an insightful discussion on private equity, corporate acquisitions and the dealmaking process. Aidan and …

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Government Consults on Reversing US/UK Double Taxation for LLC Owners

The government has launched an open consultation on reforming the way UK resident members of US limited liability companies and other ‘reverse hybrids’ are charged to UK tax.  This is an encouraging first step towards addressing a longstanding mismatch in …

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High Court dismisses judicial review challenge to farm/business Inheritance Tax changes

The Divisional Court (Lady Justice Whipple and Mr Justice Fordham) has today refused permission for a judicial review claim brought by George Martin, Thomas Martin, and the representative body Farmers and Businesses for Fair Tax Relief, represented by Collyer Bristow …

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Judicial Review begins challenging changes to IHT Agri/Business Property Relief

The High Court will today hear the judicial review challenge against what the Claimants say was the Chancellor of the Exchequer’s unlawful decision not publicly to consult on the APR/BPR changes. The case will be heard by a Divisional Court …

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Henry Richards

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High Court Lists APR/BPR Judicial Review for Urgent Hearing Before Divisional Court

Collyer Bristow LLP, acting for client Alvarez & Marsal LLP and the Claimants, Thomas Martin, George Martin and Farmers and Businesses for Fair Tax Relief, announces that the judicial review challenge to the Government’s proposed changes to Agricultural Property Relief …

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House of Lords Finance Bill Sub Committee report: a sober warning on APR/BPR reforms, consultation failure, and rushed implementation

One day after Collyer Bristow’s announcement that the High Court has granted urgent permission for the Judicial Review claim against the Government’s failure properly to consult on its Agricultural Property Relief (APR) and Business Property Relief (BPR) changes, which the …

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High Court Grants Urgent Hearing of Judicial Review into IHT Agricultural/Business Property Relief Changes

Following what the Court accepted had been “regrettable administrative delays [by court staff] in dealing with this case at various stages”, Collyer Bristow sought judicial intervention to progress the Claim.  Mrs Justice Lang DBE then immediately made an order on …

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HMRC Loan Schemes: A New Settlement Approach for Individuals Caught Up in Disguised Remuneration (Autumn Budget 2025)

Carly Russell, Partner in our Private Wealth Disputes team, shares her initial thoughts on HMRC’s newly announced settlement approach for individuals caught up in disguised remuneration loan schemes. One area of interest in the 2025 Autumn Budget was the Government’s …

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