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Global Tax News - January 2015

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

IRS private letter ruling on non-conventional real estate assets enables taxpayer to convert to REIT: key points

The Internal Revenue Service recently released a private letter ruling regarding the treatment of certain assets as qualifying “real estate” for real estate investment trust (REIT) purposes. That ruling effectively enabled...more

Overview of UK Real Estate Structures and Transactions

This Overview provides a general summary of the different corporate structures that may be used to hold, and transact in, UK real estate (such as special purpose vehicles, property unit trusts, partnerships and REITS), the...more

Breaking The Code

I saw the movie Imitation Game last weekend, which is the story of Alan Turing and his role in breaking the Enigma Code which shortened World War II and saved millions of lives. (Spoiler Alert: He did it, we won.) Turing,...more

IRS Announces That More Than 50,000 Have Enrolled In OVDP; Amnesty Program To Remain Open Indefinitely

Yesterday, the Internal Revenue Service unveiled its latest statistics on participation in its Offshore Voluntary Disclosure Program (OVDP), an amnesty program for taxpayers with undisclosed foreign bank accounts that has...more

A swift look at the OECD discussion drafts on BEPS plus one chart setting out timelines

During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to financials, the OECD released several BEPS (Base Erosion and Profit Shifting) discussion drafts,...more

Diverted Profits Tax and You: What does it mean?

A New Tax on doing business in or through the UK - The UK is on course to enact a new tax (the "DPT") with extraterritorial scope which will apply to profits arising on or after 1 April 2015 and will be applied at a...more

February 2, 2015 Deadlines for Reporting 2014 ISO Exercises and ESPP Transfers

Employers should be sure they are ready to comply with the fast-approaching deadlines for reporting 2014 incentive stock option (ISO) exercises and certain employee stock purchase plan (ESPP) transfers under Section 6039 of...more

"United States: International Cooperation, Anti-Corruption and Tax Remain Key Issues for Enforcement Authorities"

U.S. authorities continue to aggressively pursue cross-border investigations and to scrutinize closely the compliance programs of multinational corporations. Investigative activity by U.S. authorities in 2014 was particularly...more

Pension News - December 2014

In This Issue: - Budget Reforms - Pension Protection Fund - Department for Work and Pensions - Legislation - Case Law - HMRC - Public service pension schemes - On the Horizon - Excerpt from...more

IRS Treats U.S. Fund Manager as Agent of Foreign Investor – Subjecting Investor to US Trade or Business Taxation

In CCA 201501013, the IRS found that an offshore fund making loans to U.S. borrowers was engaged in a U.S. trade or business where multiple loans owned by the fund were originated by an agent of the fund. This conclusion is...more

Indiana Department of Revenue Rules Forced Disposition is Nonbusiness Income

In Letter of Finding No. 02-20140306 (Dec. 31, 2014), the Indiana Department of Revenue (Department) determined that income from the sale of two operating divisions of a business pursuant to an order of the Federal Trade...more

China Tightens Individual Income Taxation On Capital Gains From Equity Transfer

China's State Administration of Taxation (SAT) recently promulgated the Public Announcement [2014] No. 67, Administrative Measures for Individual Income Tax on Income from Equity Transfers (for Trial Implementation) (Equity...more

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent...more

New Russian De-Offshoring Rules. The Impact On Foreign Investors And Russian Businesses

The debate over the strength of the de-offshoring initiatives between Russian Government hard-liners and representatives of the business community seems to have been finally resolved as the Russian lawmakers have adopted...more

Distressed Debt - UK Tax Changes

We discuss below changes to UK tax law in respect of corporate debt which take effect from the beginning of this year which will improve the UK tax position for distressed debt of a UK company....more

Important Deadlines and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity...

Investment Advisers - Annual Compliance Reviews: All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least...more

The valuation process for LIHTC projects in financial distress: Part II

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

Tax: About the new import duty

On 28 December 2014 Ukrainian Parliament adopted the Law of Ukraine No73-VIII "On Measures on Stabilizing the Balance of Payments of Ukraine According to Article ??? of GATT 1994" (based on the draft law ?1562) and the Law of...more

Illinois Industrial Insured Self-Procurement Tax Guidance Announced

As we have previously covered in detail, at the end of its 2014 regular legislative session, the Illinois General Assembly enacted a multimillion dollar tax on Illinois companies using captive insurance arrangements. The law...more

CDFI Fund FAQ clarifies subsidiary CDE dissolution/decertification Process

In a previous Housing Plus blog post on January 7, 2015, I described the various updates to the CDFI Fund’s Frequently Asked Questions document for the New Markets Tax Credit (“NMTC”) program. The most significant update may...more

IRS Filing and Reporting Requirements for ISO Exercises and ESPP Stock Transfers

This Client Alert is intended to remind you of certain year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the “Code”), with respect to stock issued to employees (or former...more

Australian Tax Alert: Bitcoin And Crypto-Currencies: Why The GST Law Should Change

The ATO released a draft ruling on the GST treatment of bitcoin transactions on 20 August 2014. A final version of that ruling, GSTR 2014/3, was released on 17 December 2014. While the ruling deals specifically with bitcoin,...more

Annual Notices for ISOs and ESPPs due February 2, 2015

Companies that grant incentive stock options (ISOs) are required to provide notices to current and former employees who exercised ISOs during the preceding calendar year. Similar notices must be given to current and former...more

IRS Hammers Offshore Lending and Underwriting Structure

In a recent Chief Counsel Advice, in an extended analysis the IRS determined that an offshore partnership with a U.S. manager that was engaged in the finance transactions was determined to be engaged in a U.S. trade or...more

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