Business Organization Tax

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Dollar Financial UK Ltd v HMRC: When Must a Financial Intermediary Charge VAT?

Executive Summary - The decision in Dollar Financial UK Ltd v HMRC [2016] UKFTT 598 will likely be of interest to a range of participants in the lending market, and the financial services sector more generally, because...more

A “Crystal Ball” On Life After The New ERISA Fiduciary Rule

The Department of Labor’s (DOL) new fiduciary rule that is going to go in effect in April 2017 is going to have a profound change in how financial advisors work with their retirement plan clients. It’s unchartered waters,...more

Developments in Association Law 2015–2016

The Nonprofit Organizations Practice at Pillsbury has prepared this summary of significant legal and policy developments that have occurred in approximately the past year. All of these developments have potential impacts upon...more

Impact Investing and Private Foundations

Bryan Cave recently organized a half-day symposium examining the opportunities and legal considerations related to responsible and impact investing strategies. The Responsible and Impact Investing Symposium, held on November...more

Expansion of US disclosure requirements will impact foreign investors – the future of money laundering and tax enforcement

The United States is turning its attention to activities by foreign investors who use US trusts, limited liability entities, and other investment structures to conceal the ownership of criminal proceeds or foreign tax...more

Major changes in the Polish VAT regulations as of 1 January 2017

On 16 November 2016 the Sejm (lower chamber of the Parliament) adopted a bill to amend the VAT Act and certain other statutory laws, calling for numerous changes in the VAT Act and the Criminal Fiscal Code, among other laws....more

IRS Proposes Helpful Changes to "Fractions Rule" Tax Regulations

Proposed income tax regulations published by the Internal Revenue Service (IRS) on Nov. 23, 2016, amend the current regulations regarding the application of the "fractions rule" to partnerships that hold debt-financed real...more

U.K. Autumn Statement 2016: Key Implications for Investment Funds

On Wednesday 23 November 2016, Philip Hammond delivered the U.K. Autumn Statement, which included a number of announcements of relevance to the financial services industry. While relatively few new tax measures were...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Central Bank launches ORION II platform to authorise all QIAIFs applications - All QIAIFs applications (including ICAVs) will be processed via the CBI’s ORION platform allowing consistency with other legal structures and...more

UK Autumn Statement 2016: corporate

The Government has recommitted to the following reforms previously trailed in the March 2016 Budget: The Government also announced the following new initiatives...more

UK Autumn Statement 2016: finance

In the 2016 Autumn Statement, the UK government confirmed, as previously announced, that from April 2017, it is to cap the amount of tax deductions for interest to the higher of 30% of taxable earnings in the UK or the net...more

CDFI Fund Announces $7 Billion Allocation of New Markets Tax Credits

In Depth - On November 17, 2016, the US Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) announced the largest single round award of New Market Tax Credit (NMTC) allocations...more

UK Autumn Statement 2016: real estate

Interest relief restrictions - The adoption of the interest deductibility restrictions from April 2017 onwards will continue. The basic elements of the rules will remain as previously announced - a cap on deductions at...more

"Double Trouble": The Kenyan Constitution and DTAs

Controversy stalks international corporate taxation. With the integration of national economies and the promotion of Foreign Development Investments (FDIs), international corporations’ presence in multiple jurisdictions with...more

UK Autumn Statement 2016: IPT

No major changes were announced (subject to legislation to be published on 5 December), but we set out below a brief summary of the announcements which are relevant to corporates in the IPT sector....more

A Comparison of Trump and House GOP Tax Reform Proposals

With Republicans in control of the U.S. Senate, the U.S. House of Representatives and the White House starting in 2017, the federal government is now better positioned to move forward on comprehensive tax reform, with...more

Potential US Tax Reform Could Fundamentally Change the Structure of the US Tax System

With the election of Donald Trump, who pledged during the campaign to usher in fundamental tax reform (including major tax cuts), the Republican majorities in Congress have begun planning major tax changes to the Internal...more

The Times They Are a-Changin’ – Potential U.S. Tax Reform Implications of the 2016 Elections

As a result of the United States federal elections on November 8, 2016, Donald J. Trump is the president-elect, and the House of Representatives and Senate both will consist of Republican majorities. As a result, it is...more

UK Autumn Statement 2016: inheritance tax and business property relief | Insights | DLA Piper Global Law Firm

In the 2016 Autumn Statement, The Chancellor announced that reforms, originally proposed in Summer Budget 2015, to inheritance tax and business investment relief for non-UK domiciled individuals will come into effect from 6...more

UK Autumn Statement 2016

This was Chancellor Phillip Hammond's first (and last) Autumn Statement. From Autumn 2017, there will be an Autumn Budget for the coming year, which will enable greater scrutiny of complex tax provisions, followed by a Spring...more

What Proposed Tax Plans by Trump Administration and House Republicans Mean for Personal Planning

The election of Donald Trump and Republican majorities in U.S. Congress make the future of the federal transfer tax system (gift, estate and generation-skipping transfer (GST) taxes) uncertain. President-elect Trump and...more

Defenses Payroll Tax Fraud

Prosecution for payroll tax fraud is a high priority for the IRS and Department of Justice. Payroll tax fraud occurs in several manners, including false worker classification as independent contractors, understatement of...more

Limited Liability Companies: A Primer for the Canadian Finance Lawyer

The use of limited liability companies in the United States has expanded dramatically over recent years. A limited liability company (LLC) offers its owners protection from liability like a corporation, but with the advantage...more

Things That Won’t Help A Retirement Plan Sponsor Limit Their Liability

When I was a teenager, we were told that eating oat bran would lower cholesterol and it didn’t. We’re told that cracking our knuckles will cause arthritis and it doesn’t. We’re told that going outside when it’s cold with wet...more

Year-End Tax Planning with Tax Credit-Funded Scholarships

The Alabama Accountability Act provides state income tax credits to certain donors who make contributions to a state-approved scholarship granting organization (SGO). Alabama’s neediest school children can be helped at little...more

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