Weil Tax BLOG - Feed https://tax.weil.com/contributor/molly-syme/ Views and developments from the Tax Department at Weil Fri, 14 Aug 2026 20:00:03 +0000 hourly 1 The Odyssey continues: HMRC consults on the taxation of UK members of US LLCs and other foreign reverse hybrids https://tax.weil.com/insights/the-odyssey-continues-hmrc-consults-on-the-taxation-of-uk-members-of-us-llcs-and-other-foreign-reverse-hybrids/ Thu, 30 Jul 2026 09:26:39 +0000 Oliver Walker Alex Ereira Molly Syme https://tax.weil.com/?p=2679 You would be forgiven for assuming that a “reverse hybrid” is some chimeric monstrosity from ancient mythology, lurking at the edge of the map to gobble up passing heroes. In the world of international taxation, the reality is less fanciful – the term refers instead to foreign entities which are transparent for tax purposes in

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]]> You would be forgiven for assuming that a “reverse hybrid” is some chimeric monstrosity from ancient mythology, lurking at the edge of the map to gobble up passing heroes. In the world of international taxation, the reality is less fanciful – the term refers instead to foreign entities which are transparent for tax purposes in

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]]> Use, Still Not Abuse: Burlington and Treaty Benefits https://tax.weil.com/insights/use-still-not-abuse-burlington-and-treaty-benefits/ Fri, 29 May 2026 16:24:15 +0000 Oliver Walker Enda Kerin Ross Power Molly Syme https://tax.weil.com/?p=2661 The Court of Appeal’s decision in The Commissioners for HMRC v Burlington Loan Management DAC [2026] EWCA Civ 461 marks the latest stage in a significant treaty tax dispute that has now been decided in favour of the taxpayer at three successive levels. It provides important reassurance for secondary debt market participants and other taxpayers

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]]> The Court of Appeal’s decision in The Commissioners for HMRC v Burlington Loan Management DAC [2026] EWCA Civ 461 marks the latest stage in a significant treaty tax dispute that has now been decided in favour of the taxpayer at three successive levels. It provides important reassurance for secondary debt market participants and other taxpayers

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]]> You’re welcome to join but you can’t leave: The UK’s Proposed Re-domiciliation Regime https://tax.weil.com/insights/youre-welcome-to-join-but-you-cant-leave-the-uks-proposed-re-domiciliation-regime/ Fri, 15 May 2026 16:13:51 +0000 Oliver Walker Ellie Marques Molly Syme https://tax.weil.com/?p=2655 On 25 March 2026, the Department for Business and Trade published its consultation on implementing a UK corporate re-domiciliation regime, a mechanism that would, for the first time, allow a foreign-incorporated company to change its place of incorporation to the UK whilst preserving the company’s existing legal identity. This consultation is the next step in

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]]> On 25 March 2026, the Department for Business and Trade published its consultation on implementing a UK corporate re-domiciliation regime, a mechanism that would, for the first time, allow a foreign-incorporated company to change its place of incorporation to the UK whilst preserving the company’s existing legal identity. This consultation is the next step in

The post You’re welcome to join but you can’t leave: The UK’s Proposed Re-domiciliation Regime appeared first on Weil Tax BLOG.

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