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Overview of the Taxation of Foreign Currency

In this Newsletter: - Determination of the Functional Currency and Definition of a “QBU” - Section 988 — Non Functional Currency Transactions - Section 986 — Translation Rules for Earnings and Profits and...more

Transfer pricing: US readies adoption of OECD's country-by-country reporting requirement – implications for US taxpayers

The US Treasury Department has announced plans to implement a country-by-country (CbC) reporting requirement starting for fiscal years beginning in 2016 as set out in the guidance issued by the Organisation for Economic...more

Tax Policy Update

NUMBER OF THE WEEK: $42,268. The projected average taxable income of all tax returns in 2015, according to the Joint Committee on Taxation’s Feb. 27 report on “Fairness and Tax Policy.” The report also projects that the top...more

FinCEN Imposes Significant Fines In a Warning to Adhere to Due Diligence Requirements

In its recent decision to impose $20 million in sanctions upon Oppenheimer and Co. for the company’s failure to maintain internal controls to promote enforcement of the Bank Secrecy Act (BSA), FinCEN revealed the emphasis it...more

Welcome Tax Measures Announced at the PDAC 2015 Convention

On Sunday March 1, 2015, the Honourable Joe Oliver, Federal Minister of Finance addressed the Prospectors & Developers Association of Canada (“PDAC”) at the annual PDAC Convention in Toronto and announced certain proposals...more

Insigh: Capital Markets: Tips for Taps

Following a successful bond issuance, an issuer may consider a “tap” issuance as a way to access further funding. White & Case offers some “Tips for Taps” for issuers and underwriters in accessing the capital markets...more

Relief from the BEIP Freeze?

Unexpected relief may be coming for companies that are owed millions in unpaid incentive grants from New Jersey. The Business Employment Incentive Program (known as BEIP) provided companies with grants of up to 80% of...more

Tips and Traps Regarding the Statute of Limitations and Signing Statute Waivers

As you end your telephone conversation with the revenue examiner, you think to yourself, “Thank goodness, this one is finally over!” The audit of your biggest client started over three years ago, and has seemingly dragged on...more

IRS Releases First Private Letter Ruling on Small Redemption Limitation

On October 21, 2013, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Final Treasury Regulations to provide relief under Section 382 for small redemptions. These regulations provide taxpayer...more

Fifth Circuit Holds that Loss on Abandoned Securities is Ordinary Loss

Wednesday, the Fifth Circuit issued its decision in Pilgrim’s Pride and held that a loss on abandoned securities is ordinary. The Fifth Circuit rejected the IRS’s argument that Section 1234A and Section 165(g) apply to treat...more

Hong Kong Government to Extend Existing Offshore Funds Tax Exemption to Private Equity Funds

The Hong Kong government has announced in its latest budget a planned extension of the existing offshore funds tax exemption to bring offshore private equity funds investing in or through Hong Kong, within its scope. The...more

Tax Policy Update

NUMBER OF THE WEEK: $160,000. The value of one gift bag at the Oscars on Sunday night. According to the Internal Revenue Service, contents of the gift bags cannot be treated as gifts for federal income tax purposes because...more

Accountant and Attorney Liability Newsbrief - Winter 2015

In This Issue: - The Affordable Care Act and CPAs: It Takes a Village - U.S. District Court for District of Massachusetts Holds Testator’s Attorney Can Be Held Liable to A Beneficiary - New Jersey...more

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

CSSF Reminder Regarding Nomination of Depositaries of Bearer Shares - The Luxembourg regulator for the financial services industry (CSSF) has issued a press release and a FAQ in relation to the immobilization of bearer...more

Spotlight on Tennessee: Proposed Revenue Modernization Act

Governor Haslam's Administration has very recently proposed far-reaching amendments to Tennessee's tax laws. These proposed amendments are included in Senate Bill 603/House Bill 644, known as the Revenue Modernization Act...more

Insurance Topics We Will Be Watching in 2015

With the first month of the year behind us, this report outlines major insurance topics that we will be watching throughout 2015. Forces, trends and events that we believe will affect regulation, transactions and...more

China's Tax Administration Issues New Rules Governing Taxation of Offshore Indirect Transfers

On February 3, 2015, the PRC State Administration of Taxation (“SAT”) released the Announcement of SAT Concerning Several Matters Relating to Corporate Income Tax on Indirect Transfer of Properties by Non-tax Resident...more

Is a Distribution of Previously Taxed Income “Exempt from Tax”?

A U.S. shareholder of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of the CFC’s subpart F income and/or the amount determined under Section 956 with respect to such...more

Favorable German tax regime for partnership-type AIFs expanded

The German Federal Ministry of Finance has recently issued guidance that broadens the favorable tax regime for investment partnerships applicable to closed-end alternative investment funds (AIFs). The following Dechert...more

New York State Division of Tax Appeals Renders Long-Awaited Decision Regarding Corporate Franchise Tax Sourcing of Services and...

For years, both the New York State Department of Taxation and Finance (the “Department”) and the New York City Department of Finance have aggressively sought to classify receipts generated by electronic or online service...more

Sound Bites from Infocast Wind Finance 2015

The Infocast Wind Power Finance & Investment Summit 2015 was held from February 10 to 12 in San Diego. Below are selected sound bites regarding the tax equity market and other finance related matters....more

Control Transactions in the UK Mid-Market

In a number of transactions in the UK mid-market in which we have been involved recently, we have noted a departure from the traditional private equity buy-out model, whereby the sponsor acquires 100% of the target and...more

The ERISA Litigation Newsletter - February 2015

The Supreme Court cast a ray of sunlight for employers by rejecting the use of a problematic inference in adjudicating claims for retiree benefits brought pursuant to collective bargaining agreements. For many years, the...more

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more

Tax Newsletter - November/December 2014 (China & Hong Kong)

Editorial Note: Welcome to the latest issue of our Tax Newsletter. A number of developments have taken place in the PRC and Hong Kong that could be of legal and tax significance to your businesses. In the PRC, the...more

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