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Taxing Non-Residents on Capital Gains from UK Residential Property – UK Government Consults on New Rules

The UK does not generally impose tax on capital gains of non-UK residents in relation to real estate properties in the UK. However, the Government has announced that tax will be imposed on future capital gains made by non-UK...more

Mortgage Recording Tax Implications for Mortgages Securing Revolving Credit Lines

In New York, a mortgage recording tax must be paid when a mortgage is recorded. The amount of the mortgage tax is equal to a percentage of the principal amount of the indebtedness secured by, or which may be secured by, the...more

UK Budget 2014: corporate, finance and real estate tax highlights

We set out below a summary of key items of interest announced by the UK’s Chancellor in the Budget on 19 March 2014 relating to businesses, corporate and finance taxation and real estate taxation. Much of what was announced...more

Tax Measures in the 2014 UK Budget

UK government continues to support growth and build on economic recovery. On 19 March, UK Chancellor of the Exchequer, George Osborne, released the UK’s 2014 budget. From a business tax perspective, the budget...more

UK Budget Speech - Key Points

The UK's Chancellor of the Exchequer, George Osborne, delivered his annual Budget Speech on 19 March 2014. More details of measures announced will be known when a new draft of the Finance Bill 2014 is published on 27 March. A...more

2014 U.K. Budget: Impact on Alternative Asset Managers

Chancellor George Osborne delivered his fifth coalition Budget today. In a wide-ranging statement, there are a significant number of tax-focused proposals that will make changes across the U.K. tax system. Some of these...more

Chairman Camp’s Tax Proposals Would Affect REITs and Real Estate

Chairman David Camp (R-MI) of the U.S. House Ways and Means Committee recently issued a discussion draft of a comprehensive tax reform proposal which would materially modify the taxation of REITs and real estate related...more

IRS Changes Course And Provides Safe Harbor For "Real Estate Professionals" In Net Investment Tax Final Regulations

Section 1411 of the Patient Protection and Affordable Care Act (the "ACA") levies a new 3.8% tax on "net investment income" (the "NII Tax"). Among other things, the net investment income subject to the NII Tax includes...more

PA Tax Law News - February 2014

In This Issue: PA Governor's Budget Proposal Preserves Capital Stock/Franchise Tax Phase-out; Shopping Guides and Inserts; Documentation Requirements for Sales of Fuel Oil; Property Tax Notes; and PA Issues on Appeal -...more

IRS Issues Long-Promised Guidance Following Historic Boardwalk Decision

To welcome in the new year, the Internal Revenue Service (the “IRS”) issued Rev. Proc. 2014-12, 2014-3 I.R.B. 415, to provide administrative guidance to the federal historic tax credit industry in the aftermath of the Third...more

Southeast State & Local Tax: Important Developments - January 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of recent legislation around the U.S. INDIVIDUAL INCOME TAX - Virginia Income Tax Treatment of...more

2014 Brings Changes In Pennsylvania Realty Transfer Tax

Act 52 of 2013 amended many provisions of Pennsylvania state taxes, including some relatively minor changes to the realty transfer tax that took effect on January 1, 2014. The most significant change to the realty transfer...more

RETT: Decrees on anti-RETT-blocker legislation and Federal Tax Court ruling

The German Tax Authorities’ interpretation of the recently introduced Sec. 1 para 3a RETTA goes beyond just preventing RETT-blockers. Within the framework of the Act on the implementation of the Directive on...more

RETT: Reentry of partner in property owning partnership

Transfer of interests leads to loss of qualification as a former partner within the meaning of Sec. 1 para 2a RETTA. The Federal Financial Court of Germany recently decided that real estate transfer tax (RETT) is due...more

BFH: Grunderwerbsteuer bei Wiedereintritt eines Gesellschafters in die Personengesellschaft

Verlust der (Alt-)Gesellschafterstellung in einer Personengesellschaft i.S.d. § 1 Abs. 2a GrEStG durch zivilrechtlich wirksame Übertragung des Mitgliedschaftsrechts. In einem kürzlich veröffentlichten Urteil (II R 3/11)...more

Grunderwerbsteuer: Verwaltungserlass zur Anti-RETT-Blocker Gesetz und Nichtanwendungserlass zu BFH-Urteil

Erlass zu § 1 Abs. 3a GrEStG: Interpretation der Finanzverwaltung geht über die Verhinderung von RETT-Blocker Strukturen hinaus Im Rahmen des Amtshilferichtlinien-Umsetzungsgesetzes vom 26. Juni 2013 hat der Gesetzgeber...more

Real Property, Financial Services & Title Insurance Case Law Update: Week Ending January 3, 2014

I. FLORIDA STATE CASES – SARA WITMEYER - - Discovery: guarantors who moved to set aside stipulation to deficiency judgment not entitled to depose corporate representatives of foreclosing plaintiff and assignee of final...more

Calif. Taxpayers: You Can['t] Check Out Any Time You Like

For California's high-earners and business owners, Proposition 30's passage in November 2012 was a "cross the Rubicon" moment. First, Proposition 30 increased tax rates retroactively to the beginning of 2012....more

Alabama Tax Developments: 2013 Year in Review

Our final Alabama SALT Alert of 2013 summarizes the major legislative, judicial, and administrative developments affecting Alabama taxpayers with respect to income, transactional, and property taxes so far this year. The 2013...more

Revival of REIT Rulings Could Mean Good News for Companies with Non-Traditional Assets Considering Becoming REITs

In recent years, there has been a considerable expansion of the types of companies holding non-traditional real estate assets that have elected to become real estate investment trusts for US federal income tax purposes...more

Italy Real Estate Update – November 2013

A NEW TAX FRAMEWORK FOR REAL ESTATE TRANSACTIONS: A FEW CERTAINTIES AND SEVERAL DOUBTS PENDING THE CLARIFICATIONS FROM THE TAX AUTHORITY - Starting from 1 January 2014 significant changes will come into effect with...more

Proposed Legislation Would Curb JP Morgan’s Potential Multi-Billion Dollar Tax Windfall

Late last month, we commented on JP Morgan Chase’s $5.1 billion settlement with the Fair Housing Financing Agency (FHFA), as conservator of Fannie Mae and Freddie Mac. The Wall Street Journal has since reported that JP Morgan...more

1031 Exchanges with a Twist

Now that the recession appears to be fading into memory, Section 1031 Exchanges are on the rise. Section 1031 of the Federal Tax Code allows property owners to defer taxes by exchanging the sale property into one or more...more

GST & Real Property Leases – Implications Of The MBI Case

The Full Federal Court recently handed down its decision in MBI Properties Pty Limited v Commissioner of Taxation [2013] FCAFC 112 ("MBI Case"). The decision supports the view that neither the vendor or purchaser of a...more

Some Practical Risk Management Steps for Any Land Trust

I. Perpetual Calendar—Make Sure You Have Time for Reasoned Decisions—Stop trying to remember so much, reduce your stress, and avoid the risk of missing an important date. Every item that you can record onto a perpetual...more

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