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Classifying Entities and the Meaning of ?Tax Transparency?' breaks new ground in explaining comprehensively the rules for classifying entities and the meaning of ?tax transparency? in UK tax law. Imposing UK tax on an entity or those linked to it involves understanding what kind of entity is being dealt with, especially when it is formed outside the UK. Is it a company, a partnership, a trust or something else? This often involves considering whether the entity is ?tax transparent? and, if so, what that means. The UK tax rules for classifying entities are notoriously vague, and there is no single UK meaning of ?tax transparency?

The thesis begins by exploring the main UK tax law definitions of those legal persons which are relevant for direct tax purposes. In particular, it explores the law, practice and tax authority guidance (such as it is) for classifying entities formed outside the UK. In so doing, it considers in detail the distinction between a "partnership" and a "company" for UK tax purposes, and the problems this raises. The thesis then considers the UK criteria for defining certain kinds of trust for UK tax purposes, including non-UK entities with trust-like characteristics such as foundations. It then considers to what extent the UK direct tax regime treats trusts and similar non-UK arrangements as "transparent". It also analyses the different kinds of "transparency" which may apply in relation to such trusts and arrangements for UK direct tax purposes. The next part of the thesis begins with a more general discussion of what "transparency" may mean in the context of taxation (not just direct taxation) and taking into account the new "transparent entities" provision in Article 1(2) of the OECD Model 2017, and the related OECD Commentary. It concludes that there is no single concept of "transparency" for tax purposes (a conclusion already foreshadowed in the first two chapters) and that it may legitimately mean different things in different contexts. This conclusion paves the way for a detailed analysis of the varying degrees to which "transparency" is a relevant concept in relation to UK taxes which are not taxes on income and gain (notably Inheritance Tax, VAT and Stamp Duty Land Tax). The fourth part of the thesis explores the concepts of tax "transparency" and entity classification as they relate to double tax treaties and EU law. It begins with a survey of the strengths and weaknesses of the new Article 1(2) of the OECD Model 2017. It then goes on to discuss how, from limited beginnings, UK treaty policy has attempted to tackle these issues since the 1980's in its treaties relating to income and gain. It notes how the UK has been something of a follower, rather than a leader in this regard (see in particular the UK's last two treaties with the US and the latest UK treaty with France). This section then explores a number of areas where UK double tax treaties still raise problems of entity classification which are not addressed by rules resembling Article 1(2) of the OECD Model 2017 (e.g. some of the issues surrounding the Employment Income Article). Suggestions are made for improvements. The largely unaddressed problems of entity classification and tax "transparency" in the UK's estate and gift tax treaties are also considered. Lastly this part of the thesis considers the impact of EU law on questions of "entity classification" and "tax transparency". It concludes that in some respects the UK tax rules for classifying non-UK entities are not compliant with EU law. The fifth part of the thesis compares and contrasts the UK tax rules for classifying entities with the (very different) approach of the US Federal income tax, as well as the Dutch approach (which is more akin to that of the UK). It seeks to pinpoint strengths and weaknesses of both the US and Dutch approach, when compared to the UK. The last part begins by exploring why issues of entity classification and tax "transparency" matter, and not just in relation to the taxation of income and gain. This picks up themes discussed earlier. It then sets out the answers to key research questions. It ends by proposing some more general reforms of the existing UK rules.

"The explosive memoir of an FBI field operative who has worked more undercover cases than anyone in history. Within FBI field operative circles, groups of people known as "Special" by their titles alone, Michael McGowan is an outlier. 10% of FBI Special Agents are trained and certified to work undercover. A quarter of those agents have worked more than one undercover assignment in their careers. And of those, less than 10% of them have been involved in more than five undercover cases. Over the course of his career, McGowan has worked more than 50 undercover cases. In this extraordinary and unprecedented book, McGowan will take readers through some of his biggest cases, from international drug busts, to the Russian and Italian mobs, to corrupt unions and SWAT work. Ghost is an unparalleled view into how the FBI, through the courage of its undercover Special Agents, nails the bad guys. McGowan infiltrates groups at home and abroad, assembles teams to create the myths he lives, concocts fake businesses, makes the busts, and carries out the arrests. Along the way, we meet his partners and colleagues at the FBI, who pull together for everything from bank jobs to the Boston Marathon bombing case, mafia dons, and, perhaps most significantly, El Chapo himself and his Sinaloa Cartel. Ghost is the ultimate insider's account of one of the most iconic institutions of American government, and a testament to the incredible work of the FBI"--