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Brexit: What are the implications for tax law?

The precise impact of a Brexit on UK tax law is not possible to determine without knowing the terms of the exit negotiated by the UK with the EU and future government decisions. There are various ways the relationship between...more

UK tax deductibility of corporate interest expense

The 2016 Budget announced, and the UK government is currently consulting on, the biggest change in UK tax this century. Up until 1st April 2017, a tax deduction for interest costs of up to 100% of UK profits is (very broadly)...more

South Carolina Legislative Tax Update: Governor Signs Bill Amending South Carolina Tax Law to Conform With the Internal Revenue...

Differences in federal and state tax laws can cause taxpayer headaches, and often lead to incorrect state tax filings. While South Carolina’s tax code continues to treat certain items differently than the Internal Revenue...more

Sell now to avoid paying higher taxes upon disposition of goodwill and other intangibles

The 2016 Federal Budget proposed changes to the Income Tax Act (Canada), expected to come into force effective January 1, 2017, that will alter the manner in which the sale of certain intangible property, such as goodwill, is...more

EU: ECOFIN approves implementation of country-by-country reporting in the EU but fails to reach consensus on EU...

EU COUNTRY-BY-COUNTRY REPORTING: ADOPTED On May 25, 2016, the European Union’s Economic and Financial Affairs Council (ECOFIN) voted unanimously in favor of the implementation of proposed country-by-country reporting...more

Global Tax News: US Treasury's proposed §385 regulations under extreme scrutiny on Capitol Hill, in corporate tax departments: top...

As part of its ongoing effort to try to curb inversion transactions, the Treasury Department has issued proposed regulations under section 385. Section 385(a) authorizes the Treasury Department to issue regulations that may...more

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

U.S. States Expand Efforts to Collect Taxes from Out-of-State Businesses

Twenty-four years ago, the U.S. Supreme Court announced in Quill v. North Dakota, 504 U.S. 298 (1992), that in order for a U.S. state to require an out-of-state business to collect and remit sales and use taxes on its sales...more

Potential tax consequences of Brexit from a German perspective

On 23 June, the UK is holding a referendum to decide whether it should leave or remain in the European Union. A vote to leave the EU (the so-called Brexit) would not only have repercussions from a tax perspective for the UK....more

Recent Alabama Tax Developments

The Alabama Legislature adjourned sine die on May 4 bringing the 2016 Regular Session to an end. The 2017 Regular Session is scheduled to begin in February and there have been reports of a potential special session later in...more

Here’s the Deal: Georgia Governor Signs Several Significant Tax Bills

Following the conclusion of Georgia’s 2016 legislative session, Governor Nathan Deal signed into law several tax bills touching on a wide range of tax matters, including sales and use taxes, property taxes, corporate income...more

Potential tax consequences of Brexit from a UK perspective

This alert considers the possible impact of Brexit on some key UK tax aspects. However, this is only one side of the perspective: we will shortly be publishing a second article considering the potential impact of Brexit on...more

Federal Budget Update

The Australian Government continued its attack on Multinational Tax Avoidance with the release of its 2016-2017 Federal Budget. Central to its Budget initiatives is the introduction of a 40% Diverted Profits Tax on large...more

The Boomerang Effect and Tax Exempt Organizations

The Protecting Americans from Tax Hikes (“PATH”) Act of 2015, contained a provision by which tax-exempt organizations (a “TO”) could challenge revocation of exempt status by virtue of the filing of a declaratory judgment in...more

European Commission proposes public CBC reporting: key takeaways

The European Commission has published a proposed amendment to the existing EU Accounting Directive that, if adopted, would introduce a form of public country-by-country (CbC) reporting for qualifying companies in the EU. ...more

Corporate Tax Reform Proposal Would Raise Taxes on Exempts

Legislation could impose new taxes on dividend and interest income of tax-exempt entities. The Senate Finance Committee is reportedly formulating a legislative proposal to integrate the corporate and individual tax...more

Proposed Change to North Carolina Excise Tax Law for Wine Shippers

Wine Shipper permittees may soon be able to file excise tax reports on an annual basis in North Carolina, rather than monthly. A proposed bill that would allow wine shippers to file excise tax reports annually is...more

Early Stage Investment Tax Incentives Bill Introduced

As an update to our Legal Insight of December 2015 'New Tax Incentives for Early Stage Investment', on 16 March 2016 the Turnbull Government introduced legislation providing significant tax incentives to promote local and...more

David Cameron announces acceleration of new corporate offence of failing to prevent "associated persons" from facilitating tax...

The UK Government has announced the proposed introduction of a new corporate offence of failing to prevent the facilitation of tax evasion. The new offence is likely to build on draft legislation produced in...more

New Partnership Tax Audit Rules

The Bipartisan Budget Act of 2015 establishes new rules (the “New Partnership Audit Rules”) for the conduct of federal income tax audits of partnerships and the assessment and collection of income taxes resulting from such...more

'Millionaire's Tax' Could Shake Off Ghosts of Failed Drives for Graduated Income Tax

Proposals to implement a graduated state income tax have twice been rejected by Massachusetts voters in my memory, first in 1972 and then in 1994. The margins of defeat in each case were overwhelming: 67% to 33%, and...more

Bill to Tax Vacation Home Rentals Is Alive but Not Quite Kicking

Attention, Massachusetts vacation home owners who earn money renting your properties! An Act Providing for Local Aid Enhancement is showing signs of kinetic energy....more

Predicting How the New Partnership Audit Rules Will Affect S Corporations and Their Shareholders

This column has three focal points: S corporations (of course!), the new partnership audit procedures and Jeanne Dixon. Yes, that Jeanne Dixon—the self-professed psychic who claimed to have predicted the assassination of...more

Georgia Keeps It Interesting: Legislature Passes Novel Law on Interest Rates and Refund Claims

On March 24, the Georgia General Assembly passed House Bill 960 (H.B. 960), which would adjust the statutory interest rate applicable to tax assessments and refunds and addresses other issues related to refund claims for...more

Quill Part Deux: North Dakota Lost the Nexus Battle. Will South Dakota Win the War?

On March 22nd, South Dakota Governor Daugaard signed into law Senate Bill 106 (S.B. 106), the passage of which may be the ultimate vehicle to challenge Quill at the U.S. Supreme Court. With landslide support in the South...more

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