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Congress passes tax extenders – through the end of 2014: potential impact on tax reform

In the final act of the 113th Congress, the Senate passed and sent to President Barack Obama for his signature the Tax Increase Prevention Act of 2014, extending through the end of 2014 numerous familiar deduction and credit...more

Hybrid Mismatches – UK Proposals for Implementing the BEPS Recommendations

The United Kingdom made its first substantive commitment arising out of the base erosion and profit shifting (BEPS) initiative on 3 December 2014, with the release of a consultation paper on implementing the agreed G20-...more

The Economic Development Toolbox: “The Clean-Up Hitters” – Enterprise Zone and Community Reinvestment Area Property Tax Exemptions

Capital investment projects often involve tight margins, and every single dollar counts to ensure that the project is a success. For that reason, property tax exemptions are key components of any economic development...more

2014 Year-End Tax Update

I. A LOOK BACK AT 2014 TAX MATTERS: A. Some Random Observations - ..1. This year’s update is brought to you by the letter “I,” as in “inversions.” ..2. Tired of waiting for Congress to address what they...more

Fund Sponsor Entities With San Francisco Activities May See Significant Tax Increases Under Gross Receipts Tax

San Francisco’s gross receipts tax (GRT) began phasing in this year and will be fully implemented in 2018. While the tax rates are lower than those under the previous payroll tax system, the GRT may lead to higher taxes for...more

License Renewal Reminder!

The Delaware Division of Revenue (DOR) is reminding businesses that Delaware business licenses expire at the end of December and must be renewed by December 31, 2014. ...more

The Financial Report - Volume 3, No. 22 • December 11, 2014 (Global)

Discussion and Analysis - Earlier this week, The Wall Street Journal published a special Journal Report entitled “CEO Council.” The tag line for the report ominously states: “At the annual meeting of The Wall Street...more

Diverted Profits Tax – First Thoughts

The UK Government intends to introduce a 25% “diverted profits tax” (DPT) from 1 April 2015. The tax is designed to catch the artificial erosion of the UK corporate tax base by multi-nationals that avoid establishing a...more

Via Libera Alla Voluntary Disclosure: Gli Aspetti Principali Della Disciplina In Attesa Della Pubblicazione In G.U.

E' in attesa di pubblicazione sulla Gazzetta Ufficiale il testo di legge approvato giovedì 4 dicembre dal Senato in materia di rientro dei capitali dall'estero (c.d. Voluntary Disclosure o Collaborazione Volontaria). Oltre...more

Auto Notes - December 2014

In This Issue: - Retail Vehicle Installment Sale Contracts Now Regulated under PA Consumer Credit Code’s Motor Vehicle Sales Finance Provisions - Arbitration Clauses Referencing American Arbitration...more

“Deoffshorization” measures

On 24 November 2014 the Russian President signed Federal Law No. 376-FZ “On amending parts one and two of the Tax Code of the Russian Federation (in the part related to taxation of profits of controlled foreign companies and...more

Seed Capital reVIEW—2nd Half of 2014

Welcome to the second edition of Seed Capital review, written by members of the entrepreneurial Services Group at Gray Plant Mooty. as with our prior report, this version analyzes seed and angel capital financings by...more

"UK Government Announces New 25 Percent Diverted Profits Tax"

On Wednesday, the U.K. Government released draft legislation to be effective on 1 April 2015, which will impose a “diverted profits tax” (DPT) at 25 percent of the amount of profits deemed to have been diverted from the U.K....more

Draft Finance Bill 2015: Key Implications for U.K.-Based Alternative Asset Managers and Their Funds

Following not quite so hotly on the heels of the Autumn Statement as some would like, the U.K. government has now published draft legislation for inclusion in next year’s Finance Bill. ...more

Tax Alert: Commissionnaires and Other PE Structures under Scrutiny as Part of BEPS

The OECD has recently published a discussion draft on the portion of its BEPS action plan dealing with permanent establishments and has titled this paper, “Preventing the Artificial Avoidance of PE Status 1 The title itself...more

Autumn Statement 2014

Yesterday, the Chancellor of the Exchequer delivered the UK 2014 Autumn Statement. Below we summarise some of the main announcements: Taxation of multi-nationals - Diverted profits tax (aka the "Google tax")...more

FATCA in Cayman: Deadline Approaches

The deadline for compliance with both US FATCA and UK FATCA fast approaches. Cayman entities which are classified as Financial Institutions are within the scope of FATCA. A typical Cayman fund will fall within the...more

Guindon: SCC Hears Arguments in Penalty Case

The Supreme Court of Canada heard oral arguments today in the case of Guindon v. The Queen (Docket No. 35519). At issue in the case is the nature of the third-party penalty in section 163.2 of the Income Tax Act....more

A new UK withholding tax exemption for privately placed debt

The Chancellor of the UK Exchequer, George Osborne, announced in the 2014 Autumn Statement on Wednesday a new targeted exemption from UK withholding tax for interest on qualifying privately placed debt. The exemption is a...more

Bank, CFO Settle Accounting Charges with SEC

The SEC filed settled accounting actions with a financial institution and its CFO, keyed to a restatement. The accounting issue focused on deferred tax assets and the failure to have the related reserve. In the Matter of...more

Autumn Statement 2014

On December 3, 2014, George Osborne delivered his Autumn Statement. Traditionally, the purpose of this has been to update economic projections and department spending allocation, but increasingly it includes statements...more

2014 Extenders Clear the House

For many years now, Congress has contributed to tax uncertainty by extending certain favorable tax provisions on a year by year basis. Thus, for example, in 2014 these extenders have expired. Neither the IRS, who has to...more

Final regulations on qualified longevity annuity contracts

An ongoing focus for the IRS and the DOL has been trying to ensure that individuals have a regular stream of income for the duration of their lives. In connection with this goal, in July of this year, the IRS released final...more

2014 Proskauer Hedge Funds and Other Private Funds Annual Review

This year we saw a flurry of regulatory activity targeting investment advisers and hedge funds, private equity funds and other private funds (collectively, private funds). The following annual review is a summary of some of...more

New Accounting Standards Could Profoundly Impact Incentives Transparency

Executive Summary - The Governmental Accounting Standards Board (“GASB”) has issued an exposure draft of a proposed statement (the “Statement”). The Statement, for the first time, would set uniform minimum disclosure...more

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