James Ross

James Ross

McDermott Will & Emery

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Latest Publications


Focus on Tax Strategies & Developments - March 2015

In This Issue: - U.S. International Tax Policy: 10 Questions for 2015 - The New UK Diverted Profits Tax - France Implements Horizontal Tax Consolidation - China’s New General Anti-Avoidance Rules: An...more


The UK’s New Diverted Profits Tax

The UK Treasury has published the draft legislation for the new Diverted Profits Tax (DPT), which it plans to introduce from 1 April 2015. This has been unofficially described as the “Google Tax”, and represents part of the...more

12/17/2014 - Corporate Taxes Google Tax Multinationals UK

Hybrid Mismatches – UK Proposals for Implementing the BEPS Recommendations

The United Kingdom made its first substantive commitment arising out of the base erosion and profit shifting (BEPS) initiative on 3 December 2014, with the release of a consultation paper on implementing the agreed G20-...more

12/17/2014 - BEPS EU G20 Hybrid Plan International Tax Issues OECD Tax Loopholes UK

Focus on Tax Strategies & Developments - November 2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

11/12/2014 - Corporate Taxes FATCA Income Taxes Inversion Mortgages Real Estate Market REIT Spinoffs Subpart F Tax Structuring

Focus on Private Equity - April 2014

In This Issue: - Private Equity Firms Face Potential Liability Under Plant Closing Laws - Incentivising Management Across the Pond - Excerpt from Private Equity Firms Face Potential Liability Under Plant...more

4/10/2014 - Private Equity Restricted Stocks WARN Act

Death of the Salaried Partner? Wide Ranging Changes to LLP Member Taxation To Come Into Force on 6 April 2014

Wide ranging changes to the way in which LLP members are taxed are due to take effect on 6 April 2014. LLPs and their members, particularly those in professional service and private equity/fund management firms, should,...more

2/13/2014 - Income Taxes LLPs Partnerships Wages

Employers With Share Option Schemes Take Note…

A recent decision of the United Kingdom’s First Tier (Tax) Tribunal has provided a timely reminder of the importance for employers of notifying their employees of the requirement to promptly reimburse the employer for income...more

5/23/2013 - EU Income Taxes Stock Options Tax Liability

UK Supreme Court Confirms Privilege Applies Only to Advice Provided by Members of The Legal Profession

The long-awaited decision in the Prudential case was handed down by the UK Supreme Court on the morning of Wednesday 23 January. ...more

1/25/2013 - Attorney-Client Privilege Legal Advice Privilege Prudential

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