Client Alert

| December 8, 2011

Fundamental reform of the United Kingdom controlled foreign company regime marks progress towards the United Kingdom becoming a competitive location for international holding companies in the insurance industry

A complete recasting of the UK controlled foreign company ("CFC") tax regime is intended to complete the UK Government's corporate tax reforms, with the stated objective of creating the most competitive tax system in the G20 and making the United Kingdom the best location for corporate headquarters in Europe.

This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383