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International Tax News - December 2014

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS - The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015. The government has published...more

UK Finance Bill 2015 -- Draft Clauses Published

Draft clauses of the UK Finance Bill 2015 were published on 10 December 2014. They will now be the subject of consultation until 4 February 2015. This Alert provides more details on the most significant measures contained in...more

UK Capital Gains Tax For Non-UK Residents: Government To Go Ahead With Plans To Impose CGT On Sales Of Residential Property From...

The government has published detailed proposals for imposing a capital gains tax (CGT) charge on non-UK residents who dispose of UK residential property. The new charge will take effect from April 2015 and will apply to all...more

Release of Report on the Impact of Foreign Investment on the Housing Market

The House of Representatives Standing Committee on Economics (Committee) released its report on Foreign Investment in Residential Real Estate on 27 November 2014 (Report). As a response to concerns continually raised...more

UK Autumn Statement 2014

Today’s Autumn Statement saw financial institutions hit by a surprise proposal to limit the proportion of their profits which can be reduced by the carry forward of past losses, which will mean tax is paid on those profits...more

Autumn Statement 2014: Key Implications for U.K.-Based Alternative Asset Managers and Their Funds

Shortly after 12.30 p.m. today, the U.K. Chancellor of the Exchequer, George Osborne, delivered the last Autumn Statement before next year’s general election....more

Tax Measures in the 2014 UK Autumn Statement

Announcements support UK growth and prevent tax avoidance. On 3 December, UK Chancellor of the Exchequer George Osborne made a number of tax-related announcements in the 2014 Autumn Statement. Given the government’s...more

UK Chancellor of the Exchequer Issues Annual Autumn Statement

UK Chancellor of the Exchequer George Osborne delivered his annual Autumn Statement on 3 December 2014. This Alert highlights the key contents of the statement, but the detail of the proposals will become apparent only on the...more

Credit Crunch Digest - October 2014

This issue of the Credit Crunch Digest focuses on estimated Forex-related fines and exposure; requests by U.K. authorities for additional funding to investigate rate-rigging and Forex manipulation; a guilty plea in connection...more

REITs and the Alternative Investment Fund Managers Directive

The implementation of the Alternative Investment Fund Managers Directive throughout the European Union may have implications for REITs in the United States if they are determined to be alternative investment funds or “AIFs”....more

International Estate Planning and the Question of Domicile

Home is where the heart is, right? Unfortunately, the matter is not quite that simple when it comes to international estate planning. Establishing where you home – referred to officially as your domicile by attorneys and the...more

Prediction 2015: Chinese investment wave will create many opportunities in the US

As the Chinese economy continues to become more important globally, we are seeing a shift in Asian investment in the United States, particularly in California. Chinese investors will become even more active and influential...more

International Estate Planning: Establishing Your Domicile

In one of our recent blog posts, we discussed the legal term “domicile” and outlined exactly why it is so important to establish the correct domicile during the estate planning process. If you are part of an international...more

DOJ Criminal Cartel Enforcement: Six-Month Summary

This is the first in what we expect to be a series of updates on DOJ criminal actions in the cartel area. Here, we look at highlights over the last six months in the DOJ’s investigations of the auto parts industry, LIBOR, and...more

Understanding United States Estate Tax Treaties & Gift Tax Treaties

Purchasing foreign property often comes with being closer to family, rewarding cultural experiences, international adventure, and the realization of long-held dreams. It could also mean having a home away from home in a...more

Orrick's Financial Industry Week in Review

EBA Consults on RTS on Contractual Recognition of Write-Down and Conversion Powers under BRRD - On November 5, the European Banking Authority (EBA) published a consultation paper on draft regulatory technical standards...more

Tax Talk -- Volume 7, No. 3 -- November 2014

In This Issue: - IRS Clarifies Deadline for Correcting Withholding Documentation - Consent Payment Modifying Contingent Payment Debt Instrument Must be Tested for Significance - IRS Concludes Correction of Error...more

CFPB Report Highlights Errors In Mortgage And Student Loan Servicing

On October 28, the CFPB released the fifth edition of its Supervisory Highlights report. The report highlighted the CFPB’s recent supervisory findings of regulatory violations and UDAAP violations relating to consumer...more

Insurance Brokers to be the gatekeepers for unauthorised foreign insurers in North Queensland

The announcement last week of the establishment of an aggregator website for North Queensland strata, home building and home contents insurance coupled with a proposal to allow unauthorised foreign insurers (UFI) into the...more

Orrick's Financial Industry Week in Review

ESMA Updates its Questions and Answers on EMIR Implementation - On October 24, the European Securities and Markets Authority (ESMA) published an updated version of its Questions and Answers on the European Market...more

Federal Tax Lien Did Not Survive Death of Joint Tenant

Two individuals (Cunning and Wren) acquired real property in the U.S. Virgin Islands as joint tenants with rights of survivorship (JTWROS) in 2005. In 2010 the IRS filed a federal tax lien against Cunning in the U.S. Virgin...more

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part 3 - Inbound Investment Real...

As an undergraduate at West Point, I was a Spanish and Portuguese major. My Brazilian “thing” had already started a decade earlier as a ten year old growing up in the Panama Canal Zone seeing Pele play for his Brazilian team...more

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part II – Additional Income Tax...

I have mentioned in prior articles my affiliation with the South Florida law firm Osborne and Osborne, PA in Boca Raton. Back to the beginning! Boca Raton is where I started right out of the Army in 1987. I moved to Miami for...more

Orrick's Financial Industry Week in Review

ESMA Final Draft RTS for Central Clearing of Interest Rate Swaps under EMIR - On October 2, the European Securities and Markets Authority (ESMA) published a report containing final draft regulatory technical standards...more

Orrick's Financial Industry Week in Review

ESAs' Joint Committee Publishes Report on Risks and Vulnerabilities in the EU Financial System - On September 22, the Joint Committee of the European Supervisory Authorities (ESAs) published its bi-annual report on the...more

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