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Potential refund of Swedish withholding tax: opportunity for US RICs

In 2012, the Swedish Administrative Court of Appeal concluded that Sweden’s withholding tax rules are not compatible with EC law when Swedish withholding tax is levied on dividend payments made to a Luxembourg SICAV fund. ...more

Switzerland introduces corporate tax reform III aiming to maintain its global competitiveness: 6 key points

Anticipating ongoing pressure from the European Union and the OECD, Switzerland has launched a draft corporate tax reform, called CTR III, focusing on increasing the competitiveness of Switzerland as a global corporate...more

Germany's safe harbors to its net operating loss carryover limitation rules – or: let's make a law

Historically – meaning until the end of 2007 – the German corporate tax law provided for limitation rules on the use of tax-wise net operating loss carryovers of a corporation, where the "loss corporation," after a change in...more

Private placements: a new UK withholding tax exemption

The Finance (No.2) Bill 2015 contains provisions for an exemption from the obligation to deduct UK income tax from yearly interest paid on “qualifying private placements”. This measure was first announced on 3 December...more

Government of Québec 2015-16 Budget: A Balanced Budget and Ambitious Economic Plan

On March 26, 2015, the Quebec government (Government) unveiled the 2015-16 budget (Budget). After six years of deficits and further to a significant reduction of Government expenses, Quebec is anticipating returning to a...more

The ERISA Litigation Newsletter - March 2015

Editor's Overview - This month's newsletter discusses how to avoid liability under ERISA through plan design, including statute of limitations provisions, venue provisions, and anti-assignment provisions. Courts have...more

Innovation Districts

Last year representatives of a coalition of 11 organizations started meeting to discuss the continued development and expansion of Oklahoma City’s bioscience and technology sectors. Among other matters, the group discussed...more

Due Date for FATCA Reporting of US Accounts Is Approaching

The deadline to report US accounts by offshore funds that are organized in Model 2 Intergovernmental Agreement (IGA) jurisdictions, such as Bermuda, as required by Foreign Account Tax Compliance Act (FATCA), is quickly...more

Corporate Alert: China’s New Tax Regulation on Indirect Disposals Complicates Certain Offshore M&A Deals

In 2009, China’s State Administration of Taxation (SAT) promulgated Circular 698 to empower PRC tax authorities to re-characterize transfers by non-PRC residents of shares in offshore companies that hold equity interests in...more

Orrick's Financial Industry Week in Review

European Commission Unveils Tax Transparency Package - The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national...more

South African Hedge Fund Regulation – Here At Last

After five years of talking about the need to regulate hedge funds as a type of financial institution in South Africa, the Minister of Finance in his budget speech stated that with effect from 1 April 2015 “hedge funds will...more

UK Budget 2015 – Key Tax Measures

The Chancellor of the Exchequer’s final Budget of the current Parliament, given on 18 March 2015, was held in the shadow of the UK’s general election on 7 May 2015. With the backdrop of the UK’s GDP growth increasing,...more

UK Budget Bulletin - March 2015

The Chancellor's Budget Statement this afternoon contained a number of matters of real and immediate importance. It did however also contain details regarding measures which are either deferred or still under consideration...more

UK Budget 2015: Key Implications for Alternative Asset Managers

In a speech crammed full of digs aimed at opposition parties (and the French), the UK’s Chancellor of the Exchequer delivered his final pre-election Budget this afternoon....more

"Appeals Court Reverses IRS-Favorable Tax Court Decision in BMC Software"

On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more

Google Tax Spreading to Other Countries?

In December of last year, the UK announced a 25% tax on US multinational companies that do business in the UK but avoid paying UK tax through careful tax planning (for example, through the use of tax treaties)....more

LIHTC exit strategies: Loan sale

Note: This post is part of a continuing series on the Credit Report Blog on the subject of workouts and bankruptcies involving low-income housing tax credit (LIHTC) projects....more

U.S. Tax Court Finds Refundable State Credits Result in Taxable Income

The United States Tax Court recently determined that certain refundable tax credits issued by New York in connection with economic development activities (EZ Credits) constituted taxable income to the recipients for federal...more

New Interest Rate Thresholds

On 9 March 2015 Federal Law No. 32-FZ “On Amending Part II of the Tax Code of the Russian Federation”, dated 8 March 2015, entered into force. The Law is aimed at softening the negative tax effect on borrowings resulting...more

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

Federal Ministry of Finance Guidance on Tax for Closed-Ended AIFs - The Federal Ministry of Finance has issued guidance on 12 February 2015 that broadens the favorable tax regime for investment partnerships applicable to...more

Trading or Investment?

The case of Terrace Hill (Berkeley) Ltd provides a further insight into the distinction between trading and investment. Originally published in Tax Journal, Page 6 , on March 13, 2015....more

New Developments In The VAT Treatment Of Securitisation Servicing

HMRC are expected to consult on revisions to their published guidance to clarify the circumstances in which they will treat loan servicing in securitisation arrangements as exempt for VAT purposes....more

Year Long Pause Lifted on MLP Qualifying Income Private Letter Rulings – Proposed Regulations to be Issued

Following a year long pause, the IRS announced Friday that it has resumed its review of pending private letter ruling (PLR) requests and is accepting new PLR requests concerning MLP qualifying income under Section...more

Australian Tax Alert: The Meaning Of "Creditable Purpose" In The Australian GST Act

Justice Davies recently handed down her decision in the case of Rio Tinto Services Ltd v FCT [2015] FCA 94, reported at 2015 WTB 7 [174]. This important test case considers the meaning of the expression "creditable purpose"...more

Let the Training Begin: MTC Transfer Pricing Audits Draw Near

Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state...more

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