Prabhu Narasimhan

White & Case LLP

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UK Summer Budget 2015: Osborne's 'Big Summer Budget' – the key measures impacting business

The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more

7/14/2015 - Anti-Avoidance Banks Carried Interest Carried Interest Tax Rates Controlled Foreign Corporations Corporate Debt Tax Corporate Taxes Derivatives Federal Budget HMRC Inheritance Tax Investment Funds Labour Party Levy Resident Non-Domiciled (RND) Tax Reform UK

Private placements: a new UK withholding tax exemption

The Finance (No.2) Bill 2015 contains provisions for an exemption from the obligation to deduct UK income tax from yearly interest paid on “qualifying private placements”. This measure was first announced on 3 December...more

3/31/2015 - Economic Action Plan Income Taxes Interest Income Investment Funds Private Placements Tax Exemptions UK Withholding Tax

Ship on course but choppy waters abound! UK Budget 2015: 10 key measures impacting business

Before the Budget was announced, there was natural apprehension that, given the impending general election, the Chancellor would pander to the electorate and sail off course from this Government’s carefully navigated path...more

3/23/2015 - Anti-Avoidance Banks Capital Gains Corporate Taxes Derivatives Diverted Profits Tax Entrepreneurs Federal Budget Investment Management Loans Oil & Gas Private Placements Residential Real Estate Market Tax Credits Tax Exemptions Tax Rates UK

A new UK withholding tax exemption for privately placed debt

The Chancellor of the UK Exchequer, George Osborne, announced in the 2014 Autumn Statement on Wednesday a new targeted exemption from UK withholding tax for interest on qualifying privately placed debt. The exemption is a...more

12/8/2014 - Corporate Taxes Tax Exemptions Tax Reform UK

Stamp duty and SDRT exemption: recognised growth markets

As first announced in Budget Speech 2013, the Finance Bill 2014 abolishes, with effect from 28 April 2014, stamp duty and stamp duty reserve tax (SDRT) on transactions in shares and securities admitted to trading on a...more

6/2/2014 - Stamp Duty Land Tax Stamp Taxes UK

Fixtures Allowances in Commercial Property Transactions: Pooling and Fixed Value Requirements

New rules concerning capital allowances on the disposal of fixtures (first announced in 2011) are now in full force. The changes, which are procedural and impose additional formalities, are: - Mandatory pooling (which...more

5/27/2014 - Asset Valuations Commercial Property Owners Fixtures Forced Pooling IRS Withholding Allowances

Global Tax Report - September 2013: Intellectual Property Tax Planning

In This Issue: - United States: Benefits of Intangible Property Migrations - United Kingdom: Innovation: The Name of the Game - Germany: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Within the...more

9/16/2013 - Erosion EU Innovation Intangible Property Tax Planning UK

A nuisance called FATCA – Does the UK/US IGA make it bearable?

The introduction by the US of the Foreign Account Tax Compliance Act 2010 (FATCA) set the proverbial cat amongst the pigeons in the international loan financing markets by requiring foreign and domestic borrowers, lenders and...more

4/15/2013 - Borrowers FATCA FFI Intergovernmental Agreements IRS Lenders

India Budget 2013: Key Changes Affecting International Investors

On February 28, 2013, India’s Finance Minister presented the country’s budget for the fiscal year beginning April 1, 2013 (Budget). The Budget includes several proposals that affect international investors investing in India,...more

3/15/2013 - Business Taxes Foreign Investment GAAR India Royalties Tax-Residency Certificate

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