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UK Tax Rules on Disguised Investment Management Fees: Final Legislation Published

The UK's Finance Bill was published on 24 March 2015. It was subsequently enacted on 26 March 2015 without further amendment and became the Finance Act 2015. The "disguised investment management fee" provisions contained in...more

Cayman issues User Guide to Automatic Exchange of Information Portal

As noted in an earlier update, the deadline for the registration of Cayman Islands Financial Institutions with the Cayman Islands Tax Information Authority was recently extended to 30 April 2015. In anticipation of the...more

Australian Tax Alert - Investment Manager Regime (IMR) – Draft Legislation To Implement Element 3 Finally Released

The exposure draft (ED) legislation removes tax impediments for foreign investors investing into Australia in order to attract foreign investment and promote the use of Australian fund managers. OVERVIEW - The...more

BVI issues updated FATCA Guidance Notes

The International Tax Authority (ITA) of the British Virgin Islands has recently announced the issue of Version 2.0 of the Guidance Notes on the International Tax Compliance Requirements of the Intergovernmental Agreements...more

Due Date for FATCA Reporting of US Accounts Is Approaching

The deadline to report US accounts by offshore funds that are organized in Model 2 Intergovernmental Agreement (IGA) jurisdictions, such as Bermuda, as required by Foreign Account Tax Compliance Act (FATCA), is quickly...more

Corporate Alert: China’s New Tax Regulation on Indirect Disposals Complicates Certain Offshore M&A Deals

In 2009, China’s State Administration of Taxation (SAT) promulgated Circular 698 to empower PRC tax authorities to re-characterize transfers by non-PRC residents of shares in offshore companies that hold equity interests in...more

UK budget 2015

Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more

Orrick's Financial Industry Week in Review

European Commission Unveils Tax Transparency Package - The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national...more

European Commission Unveils Tax Transparency Package

The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national corporations. As of next year, EU members would have to declare their...more

South African Hedge Fund Regulation – Here At Last

After five years of talking about the need to regulate hedge funds as a type of financial institution in South Africa, the Minister of Finance in his budget speech stated that with effect from 1 April 2015 “hedge funds will...more

UK Budget 2015 – Key Tax Measures

The Chancellor of the Exchequer’s final Budget of the current Parliament, given on 18 March 2015, was held in the shadow of the UK’s general election on 7 May 2015. With the backdrop of the UK’s GDP growth increasing,...more

"Appeals Court Reverses IRS-Favorable Tax Court Decision in BMC Software"

On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more

Google Tax Spreading to Other Countries?

In December of last year, the UK announced a 25% tax on US multinational companies that do business in the UK but avoid paying UK tax through careful tax planning (for example, through the use of tax treaties)....more

New Interest Rate Thresholds

On 9 March 2015 Federal Law No. 32-FZ “On Amending Part II of the Tax Code of the Russian Federation”, dated 8 March 2015, entered into force. The Law is aimed at softening the negative tax effect on borrowings resulting...more

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

Federal Ministry of Finance Guidance on Tax for Closed-Ended AIFs - The Federal Ministry of Finance has issued guidance on 12 February 2015 that broadens the favorable tax regime for investment partnerships applicable to...more

Cayman Portal registration deadline extended

An update was released recently by the Cayman Islands Department of International Tax Cooperation in relation to the status of the Cayman Automated Exchange of Information Portal (Portal) and the requirement for Cayman...more

Real Estate Gazette - Issue 19 (Global)

In This Issue: - INTERNATIONAL: Key Issues For Real Estate In The Implementation Of The AIFMD Across Europe - ASIA: Understanding Four Key Changes To The Hong Kong REIT Code -...more

FinCEN Blacklists Banca Privada d’Andorra

On March 10, 2015, FinCEN designated Banca Privada d’Andorra, based in the Principality of Andorra, as a foreign financial institution of primary money-laundering concern pursuant to Section 311 of the USA PATRIOT Act...more

Ecuador Imposes Safeguard Import Tariffs

On March 6, 2015, Ecuador announced that it is imposing a balance of payments safeguard consisting of import tariffs between 5 and 45 percent on approximately 32 percent of products. The safeguard measure becomes effective on...more

Italy: Incentive Regimes for Renewable Energy Plants

The introduction of retrospective tariff cuts to photovoltaic (PV) plants and the abolition of the Robin Tax by the Italian Constitutional Court, combined with simplified regulation and taxation of new forms of debt...more

IRS Issues Further Revisions to Form 8938 Instructions

As part of the Foreign Account Tax Compliance Act (FATCA) passed by Congress in 2010, individual taxpayers are now required to report “specified foreign financial assets” on an information reporting form entitled Form 8938,...more

What Expats Need to Know Now about their Taxes, FATCA and the IRS

Are you an American abroad living in perpetual fear of the IRS? Do you wake up every morning wondering if today you’ll receive a formidable notice that the taxman cometh? You are not alone. ...more

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

EU Passes New Council Directive to Implement “EU-FATCA" - The Council Directive passed by the EU on 1 December 2014 implements the OECD’s Common Reporting Standard (CRS) in Europe. The Directive has to be implemented...more

Let the Training Begin: MTC Transfer Pricing Audits Draw Near

Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state...more

Cuba Today

One week ago, I visited Cuba with a delegation from the American Bar Association’s International Law Section. During our visit, we met with government officials, attorneys, law professors, foreign businessmen, journalists...more

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