Caleb has spent the last four years working for a US law firm advising on a wide range of corporate tax matters. His practice has been broad, with a focus on the taxation of hedge funds, private equity funds and multi-national technology companies. His advisory practice has required detailed analysis of significant policy developments focused on the taxation of highly digitalized businesses (including the UK diverted profits tax, digital services tax, offshore intangibles tax and the OECD Pillar One “unified approach”). Whilst his practice remains principally transactional, Caleb retains a keen interest in tax policy.
Caleb is due to complete his Masters in Tax Law from Oxford University in September 2020 and received the Oxford Field Court Tax Chambers Scholarship. As part of his studies, he is writing his dissertation on the double taxation concerns arising from the recent proposals to implement incremental taxes (such as the digital services tax and the OECD unified approach).
·“Practical Tax Considerations Arising From Trends in European Fund Structuring,” co-authored with Will Smith, The Hedge Fund Law Report, June 13, 2019
·“How the EU Tax-Haven Blacklist May Affect Private Funds Formed in Blacklisted Jurisdictions,” co-authored with Will Smith, The Hedge Fund Law Report, November 2, 2017
·“How Recent Developments Under BEPS May Affect Fund Managers’ Ability to Use Special Purpose Vehicles,” co-authored with Will Smith, The Hedge Fund Law Report, October 5, 2017
·“Application of the newly proposed criminal “failure to prevent” offense to a common hedge fund structure,” Hedge Fund Law Report, 2016