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Polish CIT exemption applies also to special Cypriot funds managed by a corporate body

In a recent Polish Supreme Administrative Court’s award it was confirmed that a non-UCITS fund should benefit from the Polish CIT exemption for investment funds, even if their corporate manager is contracted. The award...more

Financial Services Quarterly Report - Second Quarter 2015: OECD Discussion Draft on BEPS: Funds’ Treaty Access under Threat

The Organisation for Economic Co-operation and Development (OECD) published a revised discussion draft on 22 May 2015, in relation to Action 6 of the BEPS (Base Erosion and Profit Shifting) Action Plan (Action Plan 6), which...more

This Week In Securities Litigation

The SEC filed three actions following-up on its settled proceeding against Oppenheimer for selling millions of shares of unregistered penny stocks. Each individual settled with the agency. In addition, the Commission brought...more

New Tax Rules To Encourage Foreign Investment Into Australia

Effective 1 July 2015, the new “investment manager regime” provides a much simplified tax system for inbound foreign investors, and should be a welcome change for foreign investors who struggle with the complexities of the...more

India: Recent Developments Regarding Minimum Alternate Tax

Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place...more

Commission Payments to IC-DISC Recharacterized as Non-Deductible Dividends

In Summa Holdings, Inc. v. Commissioner, T.C. Memo 2015-119, the Tax Court recharacterized an exporter’s deductible commission payments made to an IC-DISC as non-deductible dividend payments to the exporter’s shareholders...more

Private Equity Newsletter - Summer 2015 Edition: Indian Private Equity: Taxation and Trends

With a new government at India’s center and positive macroeconomic fundamentals working in its favor, the private equity industry is expected to invest more actively into India over the short to medium term. In the past year,...more

Planning For Qualified Dividend Income When Taking Foreign Companies Public - Tax Update Volume 2015, Issue 2

Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income...more

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

Luxembourg Infrastructure Investment Vehicles - New Brochure - The Association of the Luxembourg Fund Industry (ALFI) has issued new technical guidelines regarding “Luxembourg Infrastructure Investment Vehicles”,...more

Australian Employee Share Schemes - More options to share...

From tomorrow, the way in which new employee share scheme awards will be taxed in Australia has changed and for the better. Following on from recent changes to assist companies to meet their corporate compliance obligations,...more

Financial Services Quarterly Report - Second Quarter 2015: Countdown to 1 July 2015: Accessing China and Australia via Hong Kong’s...

On 1 July 2015, two significant developments in the Asian funds space will come into effect. Hong Kong’s Mutual Recognition of Funds Scheme (MRF) with the PRC will – for the first time – allow international managers to...more

Ticking all the Right Boxes! Irish Collective Asset Management Vehicles Act 2015 Signed into Law

The eagerly anticipated Irish Collective Asset-management Vehicles Act 2015 (the “ICAV Act”) was signed into law in March 2015 and the first Irish Collective Asset-management Vehicles (“ICAVs”) have been authorised by the...more

Kruger: FX Derivatives Gains/Losses Taxed Only When Realized

In Kruger Incorporated v. The Queen (2015 TCC 119), the Tax Court held that the taxpayer could not value its foreign exchange options contracts on a mark-to-market basis, with the result that certain losses were not...more

Nowotny on Private Placement Group Variable Deferred Annuity Contracts for Tax Exempt and Foreign Investors [Video]

The Private Placement Group Variable Deferred Annuity Contract aka GAC has quietely been used by tax-exempt organizations for some time. As far as I can count, $50 billion of tax exempt transactions have utilized the GAC as a...more

Launch of Mutual Recognition of Funds Between Mainland China and Hong Kong

On 22 May 2015, the Securities and Futures Commission of Hong Kong (SFC) and the China Securities Regulatory Commission (CSRC) signed a Memorandum of Regulatory Cooperation on Mainland-Hong Kong Recognition of Funds, which...more

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

Enforcement – FCA Fines £13.2 Million for Transaction Reporting Failures - The FCA fined Merrill Lynch International (MLI) £13.2 million on 22 April 2015 for incorrectly reporting 35,034,810 transactions and failing to...more

Bureau of Economic Analysis (BEA) Form BE-10 Extension Until June 30, 2015

The BEA has posted on its website that the filing deadline for all “new filers” for the BE-10 (which is the five year benchmark survey of United States direct investment abroad) has been extended to June 30, 2015. A new filer...more

Uses of Suspicious Activity Reports by the IRS

In a recent conference the Director of the Financial Crimes Enforcement Network (FinCen) discussed the use of Currency Transaction Reports (CTR's) and Suspicious Activity Reports (SAR's) which are required to be filed by...more

New REIT Bill Coming?

In late April, Senator Orrin Hatch introduced Senate bill 915, the Real Estate Investment and Jobs Act of 2015. When a foreign person invests in property in the U.S., that person is subject to U.S. tax when he/she/it...more

"FIRPTA Reform Opens Door to Increased Foreign Investment in US Real Estate"

This afternoon, Reps. Kevin Brady (R-Texas) and Joseph Crowley (D-N.Y.) re-introduced in the House of Representatives a bill to significantly reform the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R....more

Investment Funds Update – Asia: Legal and regulatory updates for the funds industry from the key jurisdictions in Asia: Mainland...

Capital gains tax (“CGT”) has been a key issue surrounding the investment by QFIIs and RQFIIs in the Mainland Chinese securities market. Mainland Chinese tax authorities have publicly decided to retrospectively collect CGT...more

German Fund Taxation: A Roundup of Recent Developments

Germany’s fund taxation regime continues to evolve as the country further refines and reforms domestic tax laws that were subject to significant changes towards the end of 2013 – when Germany introduced new domestic tax rules...more

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

Luxembourg Fund Sector Continues to Grow - The CSSF press release 15/15 dated 26 March 2015 provides an overview of regulated UCIs at the end of February 2015 and confirms total assets under management of more than EUR...more

Investment in real estate: France-German double tax treaty changes

On 31 March 2015, the Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this...more

Developments in the Luxembourg Financial Sector

The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), has recently issued FAQs regarding the immobilisation of bearer shares and units, as well as a press release to remind...more

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