Finance & Banking Tax

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Check Cashing, Tax Evasion, Structuring and Asset Forfeiture; The Making of a Bad Day

The following fact pattern should is representative of a tax evasion and structuring case. A taxpayer receives checks in the ordinary course of business from customers. Some of those checks are deposited into the business...more

Successful Strategies for Doing Business in Asia: Malaysia (Updated)

WHAT ROLE WILL THE GOVERNMENT OF MALAYSIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Regulation of foreign investment in Malaysia is done both through legislation as well as governmental policies....more

FATCA: Update regarding US Reportable Accounts

The Cayman Islands Department for International Tax Cooperation (DITC) has advised that it is in the final stages of preparing its FATCA data to be provided to the IRS. Information on US Reportable Account Notifications and...more

Corporation or LLC? Business Organizations for Tech Startups.

One of the first actions you will take with your startup is to organize your company a separate legal entity to protect yourself from personal liability for the company’s debts. In the tech startup context, you’ll typically...more

Israeli Tax Authority Extends Deadline to Register Family Trusts and Elect Tax Regime

On June 29, 2015, the Israeli Tax Authority extended the deadline for registration of Family Trusts (sometimes referred to as Relatives Trusts), which are trusts created by a non-Israeli grantor for the benefit of one or more...more

Approval Process Disapproved: IRS Curtails the Determination Letter Program

The Internal Revenue Service (the “IRS”) on July 21, 2015, issued Announcement 2015-19, describing important changes to the determination letter program for individually designed tax-qualified retirement plans. These changes...more

Retirement Planning Strategies under the Scrutiny of the Federal Fisc

President Obama’s proposed budget for 2016 shows that some retirement planning strategies have drawn the attention of the Federal government and may be subject to future legislative limitations. The President’s proposed...more

Tax Review - August 2015

We are proud to present the next edition of our “Tax Review” which contains a selection of rulings and interpretations that had been issued or published in July 2015. We hope you will find the information provided here...more

Cyprus and Iran sign Double Tax Treaty

On 4 August 2015, the governments of Cyprus and Iran signed an agreement for the avoidance of double taxation (the Treaty). With the lifting of international sanctions against Iran, Cyprus is now uniquely positioned to act as...more

The Essential Plan Providers For A 401(k) Plan

When people are sick, especially debilitating illnesses or diseases, it’s natural for them to travel far and wide to get the best medical coverage possible. I live in Long Island, but my children were born in Manhattan...more

Pensions News - July 2015

Welcome to DLA Piper’s Pensions News publication in which we report on developments in pension legislation, guidance and case law, as well as keeping you up to speed on what to look out for in the coming months. This...more

Successful Strategies for Doing Business in Asia: Korea (Updated)

WHAT ROLE WILL THE GOVERNMENT OF KOREA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Korean government takes an active, investor-friendly role in approving and regulating foreign direct investment....more

Pension Investment Management Services - with or without VAT?

A significant cost of running a defined benefit pension scheme historically has been the VAT on investment management services. However, HMRC has recently confirmed that a European court case means employers may now recover...more

IRS Announces Changes to Determination Letter Process for Individually Designed Retirement Plans

In Announcement 2015-19, the IRS announced the elimination of the five year remedial amendment cycle for individually designed retirement plans effective as of January 1, 2017. This means that after January 1, 2017,...more

School Buses Exempted from Property Tax

While children sing the “Wheels on the Bus Go Round and Round” as they head to school, it is highly doubtful that they ponder who has to pay the taxes for those wheels. Yet, this very question arose recently in the New...more

Renewable Energy Update - August 2015 #3

Renewable Energy Focus: U.S. Senator Charles Schumer calls for changes, extension to solar ITC: PV-Tech - Aug 20: During a scheduled visit to a SolarCity factory under construction in South Buffalo, New York, U.S....more

Swiss Banks Bank Zweiplus and Banca Stato Have Entered into Non-Prosecution Agreements under the DOJ’s Swiss Bank Program

Two more Swiss banks have reached resolutions with the Justice Department under its Swiss Bank Program. Yesterday, DOJ announced that bank zweiplus ag (Bank Zweiplus) and Banca dello Stato del Cantone Ticino (Banca Stato)...more

Absurd Things About 401(k) Plans That Are True

We drive on parkways and park on driveways. Cigarettes are sold in gas stations even though smoking is prohibited there. Fat chance and slim chance mean the same thing. Phonetic isn’t spelled the way it sounds. When it comes...more

Proposed Regulations Require Significant Entrepreneurial Risk for a Service Partner's Income to be a Distributive Share

On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A) (the proposed regulations) which would treat certain partnership...more

INTERPOL and the tax man

A reader recently sent in the following questions: Can you tell me would the IRS issue a diffusion notice in a civil tax audit involving offshore banking? Would Interpol even accept a diffusion notice on a non criminal...more

Court Decisions Extend Chicago’s Transfer Tax Ordinance to Cover Mortgage Assignment

Earlier this month, in a case of first impression, the Circuit Court of Cook County, Illinois in the consolidated cases of City of Chicago v. KTCP 225, LLC, Case No. 13 L 050290, and City of Chicago v. Horizon Group XXI, LLC,...more

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

Tax Proposals in Summer 2015 Budget to Affect UK Asset Managers - The UK Summer Budget was announced on 8 July 2015, and included a number of unexpected tax proposals affecting the UK asset management industry, including...more

Successful Strategies for Doing Business in Asia: Japan (Updated)

WHAT ROLE WILL THE GOVERNMENT OF JAPAN PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Generally speaking, foreigners can conduct business in Japan on an equal legal footing with Japanese citizens. The...more

A UK home for private funds? HM Treasury consults on potential amendments to United Kingdom limited partnership legislation

HM Treasury has published a consultation paper setting out proposed reforms to UK limited partnerships law with a focus on private fund structures (the “Consultation Paper”). The consultation includes a draft legislative...more

Special Session Ends with Handful of Noteworthy Tax Bills, Predictions for Next Special Session

The first Special Session of 2015 ended on Tuesday, August 11, without accomplishing the primary objective of passing a General Fund budget for the 2015-2016 fiscal year. The Governor’s “call” for the special session included...more

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