Michael McGowan and Andy Howard Co-Author Article on Ongoing Uncertainty Over Entity Classification for U.K. Tax Purposes

August 2010

Mr. McGowan and Mr. Howard co-authored the article, “Ongoing Uncertainty Regarding Entity Classification for U.K. Tax Purposes: Swift v. HMRC,” which was published in the summer 2010 issue of the Journal of Taxation of Investments. Following a recent decision of the U.K. tax tribunal, the article explores the uncertain U.K. tax treatment of investment in a Delaware LLC in particular, as well as the U.K. approach to entity classification for tax purposes in general.