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India budget update: top points for multinationals

In an effort to jump-start a weak economy, the Indian government’s Union Budget adopts several new measures while taking a balanced approach. These are the government’s key areas of focus...more

SEC Adopts Amendments to Money Market Fund Rules

The Securities and Exchange Commission (SEC) today adopted long-awaited and highly anticipated amendments to rules under the Investment Company Act of 1940 (the 1940 Act) governing money market funds. ...more

Netherlands: New decrees on ATRs, APAs and substance requirements

One of the most attractive features of doing business in the Netherlands is the possibility to obtain an Advance Tax Ruling (ATR) and/or Advance Pricing Agreement (AP) so that foreign companies investing in or through the...more

Anti-Inversion Legislation May Impact Non-Inverted Private Equity Deals

Corporate inversions have been the target of regulatory or statutory tax proposals for many years. However, the recently attempted combination of Pfizer and AstraZeneca received prompt and more far-reaching attention in the...more

Tax “Brujeria” - Transitional Tax Planning Considerations to Move Your Business to Puerto Rico

The other day I asked the garage attendant who was of Puerto Rican (PR) ancestry and listening to Salsa music as she worked, which group was the most influential band in her estimation – La Sonora Poncena or El Gran Combo....more

SEC Requires Floating NAV for Institutional Money Market Funds; IRS Eases Tax Reporting Burden for Fund Investors

Yesterday, a divided Securities and Exchange Commission adopted rules that will require floating net asset values (NAVs) for institutional money market funds and give most money market funds the discretion to impose liquidity...more

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

Wyden’s Previous Proposals Could Signal Tax Reform Priorities

Senator Ron Wyden (D-OR) has been a strong advocate for comprehensive tax reform since he joined the Senate Finance Committee in 2005. During his tenure on the Committee, he has introduced a series of comprehensive tax reform...more

Raising Money? Don’t Forget About the Tax Credits

With many states continuing to use tax credits to seed entrepreneurial growth, entrepreneurs and legal counsel must understand the applicable state-sponsored programs and position qualifying businesses to take advantage of...more

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

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

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

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

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

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

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

Swimming in the Deep End – The Surprising Utility of Pooled Income Funds for High Net Worth Tax Planning

Overview - The old cliché about Charity is that “Charity begins at home.” The federal government has always recognized the social benefit of providing tax incentives for individual and corporate taxpayers in order to...more

Rules Will Allow Issuance of Longevity Insurance in Retirement Plans

On July 1, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final rules excluding qualifying longevity annuity contracts (QLACs) from the required minimum distribution rules (RMD...more

Introduction of the Exploration Development Incentive

In the 2014 Budget, the Federal Government announced that it would introduce Exploration Development Incentive (EDI) tax credits to encourage and stimulate growth in the junior mining industry. This is a simpler approach to...more

German Federal Government Plans Tax Exemption of INVEST – Subsidy for Venture Capital

The German Federal Government has given an important insight to its plans and future measures regarding taxation of the start-up- and VC-ecosystem in Germany by officially answer to a parliamentary request by several members...more

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