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Gerald Montagu on Muck Rack

Gerald Montagu

As seen in: LexisNexis UK, Tax Journal
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Articles

Tax insurance: taxation of proceeds and gross-up

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By Laura Jane Foley, Tom Cartwright, Gerald Montagu
| Tax Journal Verified
In the throes of a fast-paced transaction or a complicated reorganisation with a knotty tax issue that is being insured the potential tax treatment of any insurance proceeds can be an unwelcome additional complexity. But it is an element that is worth bearing in mind when considering who will be the insured and when setting the required insurance policy limit (to ensure it covers potential grossing up of the proceeds).
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Tax and the City review for March 2025

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By Mike Lane, Zoe Andrews, Gerald Montagu
| Tax Journal Verified
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Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle

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By Gerald Montagu, Elena Rowlands
| Tax Journal Verified
Lloyds Asset Leasing Ltd v HMRC [2025] UKFTT 57 (TC) concerned claims by some hundred subsidiaries of Lloyds Banking Group to surrenders of CBGR in respect of £3.8bn of losses incurred by Bank of Scotland Ireland Limited (BOSI) as a result of real estate loans that went bad in the aftermath of the 2008 crash. The not insignificant sum of £1 070 323.24 of corporation tax was at stake.
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