Now replaced by something in CTA 2009

Simon, what you need to know as most UK tax advisors don't is that in the US the dividend paid up to the checked entity will be CC income in the US probably without a tax credit so unless there are US NOLs there could be a major problem. Countless big 4 firms give bollocks advice to their US compatriates re this

Posted By: Butterworth, May 17, 23:31:45