Michael McGowan, Andrew Thomson and Emma Hardwick Author Article on U.K. Tax Treatment of Basel-III-compliant Capital Instruments

July 28, 2014

In the Summer 2014 issue of Journal of Taxation of Investments, Mr. McGowan, Mr. Thomson and Ms. Hardwick authored the article, “U.K. Enacts Tax Regime for New Additional Tier 1 and Tier 2 Regulatory Capital Instruments.” The article outlines the U.K. tax treatment of debt and equity instruments and its previous practice in dealing with regulatory capital instruments; it then discusses the regulations made by the U.K. on the treatment of Basel-III-compliant instruments, including those issued by non-U.K. institutions with branches in the U.K. The authors note that the regulations evidence the U.K.’s willingness to create a benign corporate tax environment for issuers of regulatory capital in general.