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BEPS Action 7: how the OECD's proposals to redefine a PE could affect multinationals

The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions....more

PATH Act Brings FIRPTA Changes

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed December 18, 2015, introduces significant changes to the Foreign Investment in Real Property Tax Act (FIRPTA), particularly concerning REITs. ...more

IRS Publishes Guidance for RICs that Receive Foreign Tax Credit Refunds

IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more

Split-dollar Life Insurance – A Tax-Leveraged Derivative for Hedge Fund Managers

The Emergency Economic Stabilization Act of 2008 ended the not so discrete secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an unlimited Super...more

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act,” Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...more

Annulment of the European Commission´s decision regarding the former "Spanish tax lease structure" - EU General Court Decision:...

Background - On December 17, 2015 the EU General Court of Justice (EUGC) pronounced on appeals of joined matters T-515/13 Kingdom of Spain vs Commission and T-719/13 Lico Leasing, S.A., E.F.C. and Pequeños y Medianos...more

Your daily dose of financial news The Brief – 1.14.16

So much for 2 days of optimism. Stocks took another dive yesterday, well into correction territory – NYTimes... Care to guess what that meant in Asia today (and Europe, for that matter)? – WSJ... Goldman Sachs is...more

Global Private Equity Newsletter - Winter 2016 Edition: Hong Kong Profits Tax Exemption for Private Equity Funds

The Inland Revenue (Amendment) (No.2) Ordinance 2015 (the “Amendment Ordinance”) came into effect on July 17, 2015, extending Hong Kong profits tax exemption to offshore private equity (“PE”) funds....more

New Withholding Tax Exemption for Private Placements in the UK

Interest paid by UK companies is generally subject to withholding tax at 20%. Although various exemptions apply, most notably in respect of interest payments to banks and other UK companies, and in respect of securities...more

Alert: PATH Act Gives Tax Benefits to Emerging Growth Companies and Investors

On December 18, 2015, as part of passing an omnibus spending bill for fiscal year 2016, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the "PATH Act"). The PATH Act extends, in some cases...more

New PATH Act Changes Rules for Foreign Investment in US Real Estate and for REITs

The PATH Act exempts certain foreign pension funds from taxation under FIRPTA and significantly modifies the tax rules applicable to REITs. On December 18, 2015 (Enactment Date), US President Barack Obama signed the...more

New PATH Act Modifies Tax Rules Applicable to Foreign Investment in U.S. Real Estate and Introduces a New Exemption for Certain...

On December 18, 2015, as part of the “Protecting Americans from Tax Hikes of 2015” (the “PATH Act”), President Obama signed into law provisions that make significant changes to the so-called FIRPTA rules that govern the U.S. ...more

The Private Placements Withholding Tax Exemption

The Finance Act 2015 introduced an exemption from a borrower’s obligation to withhold tax from interest payments arising on qualifying private placements. It was introduced to stimulate and grow the private placements market...more

Protecting Americans from Tax Hikes Act of 2015 Approved by Congress and Signed by the President

President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired...more

Congress Passes New Tax Laws Affecting REITs - Protecting Americans from Tax Hikes Act of 2015

On December 18, President Obama signed the Protecting Americans from Tax Hikes (PATH) Act of 2015 (the “Act”) into law. The Act provides for a number of favorable and flexible REIT-specific tax provisions, and implements...more

Proposal of significant tightening of the rules on tax credits regarding German equities

On 17 December 2015 the German Ministry of Finance (Bundesfinanzministerium) circulated its consultation draft bill on the reform of fund taxation (‘Ministry’s Draft’). The Ministry’s Draft still contains a complete revision...more

Common Reporting Standard and FATCA

2016 Compliance Update - For the past few years, FATCA has dominated the international tax compliance landscape. As that regime continues to be phased-in, a new regime – the Common Reporting Standard (“CRS”) – will begin...more

Luxembourg Publishes Bill of Law on Reserved Alternative Investment Funds

The Luxembourg Council of Government approved on 27 November 2015 the bill of law (“Bill”) on reserved alternative investment funds (“RAIF”), a new form of Luxembourg alternative investment fund (“AIF”). The Bill was...more

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

HM Treasury Publishes Draft Technical Legislative Amendments for UCITS V - HM Treasury published a consultation on 23 October 2015, including a draft statutory instrument, on technical changes to the Financial Services...more

India Eases Rules for Foreign Investment in LLPs

India has relaxed its rules for foreign direct investments (FDI) for limited liability partnerships (LLPs), with a recent abolishment of the requirement of regulatory approval for a foreign-invested LLP in India. This change...more

2015 Autumn Statement and Spending Review Released

The statement is tax light, but there is continued focus on carried interest. On 25 November, the UK Chancellor of the Exchequer George Osborne made a number of tax-related announcements in the 2015 Autumn Statement and...more

2015 Proskauer Annual Review and Outlook for Hedge, Private Equity and Other Private Funds

Proskauer has released the 2015 Proskauer Annual Review and Outlook for Hedge, Private Equity and Other Private Funds. The 88-page report is a summary of significant legal changes and developments in the private funds space...more

IRS and Treasury Issue More Guidance on “Inversion” Transactions

The Treasury Department and the Internal Revenue Service have issued additional guidance about so-called “inversion” transactions. Generally, an inversion transaction results where a U.S. corporation (“U.S. Target”) is...more

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

Latest Fund Statistics for Luxembourg Illustrate Continued Growth - ALFI has issued the fund statistics as of 30 September 2015. Luxembourg continues to be the number one location for Funds in Europe, with both number of...more

BEPS and real estate investment funds: What are sponsors to do?

The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the "Reports") after a two-year consultation period during which 62 countries and many other stakeholders (such as...more

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