Tax Journal Profiles Sophie Donnithorne-Tait

As part of its “One minute with…” series, Tax Journal profiled Akin Gump tax partner Sophie Donnithorne-Tait discussing her work, her experience and tax-related news stories.

Among the topics discussed:

• Her current work: “The majority of our clients are financial institutions—predominantly funds—many of whose investment structures will be affected by the EU tax developments contained in the Anti-Tax Avoidance Directives (for example, the interest limitation rules and the hybrids rules generally coming in from 2019 and 2020 respectively) and the impact of Brexit on US treaty eligibility. This year we have been working with clients to try to BEPS and Brexit-proof their new and existing investment structures and have found that the UK’s securitisation company regime can provide potential solutions to some of the issues.”
• Something she’s learned about her field: “How small the London tax adviser world is and how collaboratively tax practitioners at different firms tend to work together. Tax is a pretty friendly place to work in the sometimes harsh world of corporate law.”
• Brexit and the tax practice: “The most relevant issue to our client base is probably that, post-Brexit, UK investors in non-UK entities seeking US treaty benefits (e.g. to obtain exemption from withholding on US source income) will cease to qualify as ‘equivalent beneficiaries’ for the purpose of the limitation on benefits articles in the relevant double tax treaties (i.e. those between the US and jurisdictions such as Ireland or Luxembourg).”

To read the full profile, please click here.