Tax Finance & Banking

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BVI publishes draft FATCA Guidance Notes

In the latest moves towards implementation of the FATCA Intergovernmental agreements (IGAs) signed by the BVI with the US and the UK, the BVI Government has released draft Guidance Notes for public consultation. A copy can be...more

New Spanish Tax Regime for Qualifying Bond Offerings May Boost High-Yield Bond Markets

New rules will facilitate privately held companies’ access to bond financing and reassure Spanish investors. On June 28, 2014, Law 10/2014, on the organization, supervision and solvency of credit institutions (Law...more

Silk Road’s Ulbrecht Fails in Dismissal Bid, Court Strengthens Federal Bitcoin Enforcement

In another installment of the continuing saga surrounding the shuttering of the Silk Road online marketplace and arrest of its alleged creator and operator, Ross William Ulbricht (Ulbricht), a Southern District of New York...more

Analysis: The Tax And The City Briefing For July

Redemption payments - The Court of Appeal (CA) has made short work of a case where loan stock was issued without interest but with a right to redemption proceeds of 7.25% per annum on the principal amount. The outcome...more

Tax Newsletter - May/June 2014 (China & Hong Kong)

Editorial Note: Welcome to our redesigned Tax Newsletter. You will notice we have streamlined the publication and will now publish bi-monthly instead of quarterly. For major developments that may be highly...more

Applicable Federal Rates - August 2014

See Charts below for August 2014 Tax Rates....more

Reporting Foreign Account Gifts

One of the areas of inquiry that is certain to receive increased attention by the IRS and Department of Justice (DOJ) is the claim that the funds in offshore accounts were the result of a “gift”. The proper documentation of...more

Legislative Hostage -Taking/Legislative Update

This has certainly been the week of legislative hostage-taking, unhappy people and bad feelings. Although the Senate made a mid-week budget offer to the House that looked promising to us, the House's lack of enthusiasm...more

IRS Gives QLACs the Green Light: Final Regulations Issued

On July 1, 2014, the Internal Revenue Service (“IRS”) issued final regulations (“Final Regulations”) that permit employers and IRA providers to offer “qualified longevity annuity contracts” or “QLACs” under defined...more

Part 3 – The Delinquent FBAR Submission Procedures

Below is Part 3 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

SEC Issues Interpretive Advice About Verification Safe Harbors Under Rule 506(c)

The availability of the private placement exemption under SEC Rule 506 depends in large measure upon determinations that purchasers are “accredited investors” under the rules. Where there is no general solicitation, Rule...more

Focus on Private Equity - July 2014

In This Issue: - Latin American Private Equity on the Rise - Tax Considerations When Acquiring Non-U.S. Portfolio Companies—Mitigating Subpart F Inclusions - Private Equity Funds at Higher Risk of...more

Synthetic Investment in U.S. Real Estate by Foreign Investors

According to recent reports, foreign investment in commercial U.S. real estate exceeded $38.7 billion in 2013 - a 40 percent increase over 2012. Leading the way in 2013 were investors from Canada, China, Australia, Germany,...more

What Donors Need to Know About Appreciated Property

Individuals considering gifts of appreciated property to charity should be aware that not all property donations are treated equally for income tax purposes. Depending on the class of property, prior use, the donor’s holding...more

Italian Government Enacts Innovative Measures to Support Access to Finance

A new decree expands the types of entities allowed to provide loans beyond banks and financial intermediaries. Introduction - The Italian Government enacted law decree No. 91, of June 24, 2014, published on...more

IRS Announces Changes to the Offshore Voluntary Disclosure Program

As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more

Plan Sponsor Should Avoid These Retirement Plan Provider “Con Games”

The George Clooney-Brad Pitt trilogy of heist films known as Ocean’s Eleven, Ocean’s Twelve, and Ocean’s Thirteen were remembered for their twist endings, stylish pacing, and lightheartedness. Since the Ocean gang were...more

Doing Business in Canada: Investment Incentives

INVESTMENT INCENTIVES - Generally, Canadian companies are expected to be self-supporting, but for companies involved in export development, there are several types of investment incentive programs which are designed to...more

Real Estate Investment in Australia

Australia continues to be viewed as a destination of choice for global real estate investors seeking a safe haven in a well-regulated and highly transparent growth-orientated market for doing business. In addition, the...more

IRS’s Offshore Voluntary Disclosure Program: Current Streamlined Procedure

U.S. citizens and tax residents are required to report their world-wide income on their federal income tax returns. In addition, these U.S. persons are required, and have been required for some time, to separately report...more

For Love or Charity – A Charitable Bailout Using Charitable Remainder Trusts for the Sale of a C Corporation

I have personally observed in my professional travels that many taxpayers are reluctant charitable donors. However, we you remind a business owner that they only have three choices when it comes to taxes (1) Pay yourself;...more

A Guide to the Cyprus Holding Company Regime

Why set up a holding company? In essence, holding companies are set up as an effective means of consolidating ownership of operating subsidiaries. Deciding where to set up a holding company is not always a tax driven...more

Limitation on IRA Rollovers: Once Per Year Only

The Internal Revenue Service (“IRS”) has narrowed the rules relating to Individual Retirement Account (“IRA”) rollovers by withdrawing longstanding proposed rules to reflect a recent U.S. Tax Court ruling in Bobrow v....more

Part 2 - The IRS’ New 2014 Offshore Volunteer Disclosure Procedures

Below is Part 2 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. To view this Part, and all prior parts, in PDF format...more

False Foreign Gift Claims and Wire Fraud

A scheme that some dual national taxpayers have used involves claiming exemption from foreign jurisdiction taxation because they are U.S. taxpayers and then not reporting the offshore account or its income as required by U.S....more

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