Finance & Banking General Business Tax

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The struggle to attract and retain businesses and the jobs they provide has increasingly led to states and cities squaring off against others, with competing tax incentive packages the very real currency of the battle....more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

Funds Bulletin - February 2017

Funds Bulletin (a monthly round-up of topical legal, regulatory and tax issues affecting the fund industry). Features our summary of the FSCP's position paper on the impact of Brexit on financial services consumers, as well...more

Protecting Tax Deferral for A Contribution to A Partnership

When a taxpayer (“Taxpayer”) sells a property (“Property”) with a fair market value (“FMV”) in excess of Taxpayer’s basis in Property in exchange for cash in an arm’s-length transaction, the amount of gain that he realizes on...more

Singapore Eases Regulatory Regime for VC Funds to Promote Financing for Start-Ups

The Monetary Authority of Singapore has proposed a simplification of the authorisation process and regulatory framework for venture capital managers—with the goal of supporting start-ups....more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Your Daily Dose of Financial News

Former AIG chief Hank Greenberg and his co-defendant, AIG’s former CFO, reached an “unexpected” settlement last week with NY officials. The duo will fork over about $10 million in bonuses payments and admit that they...more

The Blockchain revolution: An analysis of regulation and technology related to Distributed Ledger Technologies

Blockchain is on the verge of revolutionizing how we interact in the digital world. It has far reaching applications from the Financial industry to many other sectors of the economy. The question is what is Blockchain, what...more

"Trump’s Proposed Changes to Tax, Dodd-Frank, DOL Could Impact Executive Compensation"

President Donald Trump’s campaign proposals included changes to tax rates and a promise to repeal the Dodd-Frank Act. If enacted, these proposals could have a significant impact on the way businesses handle executive...more

The New Issue Price Regulations: The Good, the Bad and the Ugly

Late last year, the Treasury Department released final Treasury Regulations (the “New Regulations”) relating to the “issue price” of tax-exempt bonds, effective for bonds sold after June 7, 2017. Because the changes imposed...more

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

Rolling Over Target Equity Into A PE Fund: Part I

For many business owners, the final step of a successful career may be the sale of their business. At that point, the investment into which the owners have dedicated so much time, effort and money is liquidated, leaving them...more

New Belgian Crowdfunding Law: Requirements and Tax Benefits

The Belgian Law of 18 December 2016 on crowdfunding will enter into force on 1 February 2017. The crowdfunding law creates a specific status for equity and debt crowdfunding platforms (referred to as “alternative...more

Corporate E-Note - January 2017

The IRS has announced it will begin treating certain syndicated conservation easement transactions and “substantially similar” transactions as “listed transactions.” Notice 2017-20 published on December 23, 2016 (the...more

IRS Clarifies New Management Contract Safe Harbors

In August, 2016, the IRS issued Revenue Procedure 2016-44, the first comprehensive revision of its management contract safe harbors since Revenue Procedure 97-13. Rev. Proc. 2016-44 built upon and amplified principles laid...more

Mexico 2017 Repatriation Tax Amnesty

A new amnesty program to incentivize the repatriation of funds kept abroad by Mexican taxpayers was launched. The program will be open until mid-2017 and participants would be obliged to comply with specific requirements,...more

Management Contracts Safe Harbors Revisited – IRS Releases Updated Guidance (Again)

Demonstrating the “user-friendly” side of the IRS, on January 17, 2017, the IRS released Revenue Procedure 2017-13 (“Rev. Proc. 2017-13”) (available here) to address many (but not all) of the comments received on the rather...more

Proposed Loss of Interest Deduction Would Boost Cost of PE Deals

Where asset acquisitions or deemed asset acquisitions are not available, the loss of the interest deduction would likely result in an increased focus on pure equity-funded transactions. Originally published on the Middle...more

Loans Between Related Entities

What Was Intended? Over the last thirty years, I have reviewed the income tax returns of many closely held corporations and partnerships. Quite often, on Schedule L (the balance sheet), I will see an entry for “other...more

New IRS Reporting Rule Could Bite Unwary Foreign Investors

There are two main sources of reporting requirements for foreign investors in the United States — the Internal Revenue Service and the Bureau of Economic Analysis. The IRS recently upped its game by requiring reports from...more

HMRC Publishes Guidance on the Tax Treatment of Clawback of Remuneration in the UK

Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...more

Amendment Protocol to the India-Singapore Tax Treaty Inked

Capital gains on alienation of shares to be taxable by India. The India-Mauritius tax treaty was amended by way of a protocol signed by the two countries on May 10, 2016—marking a landmark shift in India’s taxation...more

The IRS's Stricter(?) Stance on Regulated Investment Company Investments in Commodities - Tax Update Volume 2017, Issue 1

While the IRS's Proposed Regulations Are Not Yet Effective, RICs Should Carefully Consider Whether Their Portfolios or Policies Run Afoul of the New Rules. In order for a corporation to qualify as a regulated investment...more

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more

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