Andrew Howard

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As first published in the March 22nd issue of Tax Journal, London tax partner, Andrew Howard, examines the Court of Justice of the European Union’s (the CJEU) landmark ruling on withholding tax and abuse of rights in the Danish conduit cases. In the Danish conduit cases, the CJEU has found that the establishment of holding companies in European jurisdictions can amount to an abuse of rights in some circumstances. Abusive holding companies will not qualify for withholding tax…
In a recent The Drawdown article, “Tax Comes Under ESG Spotlight,” tax partner Andrew Howard provides commentary on how companies might approach assessing reputational risks from tax decisions in the ESG global arena. Howard notes, that in light of recent attitude shifts toward tax transparency, we may see “policymakers bring forth rules that erode confidentiality in tax affairs in favour of greater openness to the general public, not just authorities.” Click here to read the…
In May 2016, we published an alert about UK proposals to introduce new strict liability corporate criminal offences aimed at preventing the facilitation of tax evasion. Andy Howard, Tax partner in the Ropes & Gray London office, also recently recorded a short video on the topic for our Trending Legal Topics series. The UK has recently confirmed that the relevant legislation will come into effect on September 30, 2017. In this alert, we recap on…
Refusal to Stay Pending CBM Unusual Last week I discussed the creation of a “Track B” docket by the Eastern District of Texas (EDTX) and explained how this docket could force some defendants away from the more cost effective alternatives of the USPTO’s Patent Trial & Appeal Board (PTAB). On the heels of the Track B announcement, the Court issued a second denial of a stay of the patent dispute between VirtualAgility Inc., v. Salesforce.com Inc., et al. (…