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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

New Partnership Audit Rules – Plan Ahead Before the Tax Bill Arrives

by Carlton Fields on

A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more

Financial Services Quarterly Report - Third Quarter 2017: Global Update: UK Criminal Finance Act 2017: Immediate Considerations...

by Dechert LLP on

UK asset managers, non-UK asset managers carrying on business in the UK and the funds they manage are within the scope of the new corporate criminal offences of failing to prevent the facilitation of tax evasion. As the new...more

Funds Talk: October 2017 - Far-Reaching U.K. Law Creates Corporate Criminal Offense for Failure to Prevent the Criminal...

The U.K.’s Criminal Finances Act 2017 (the “Act”), which went into effect on Sept. 30, 2017, significantly expands the U.K.’s ability to prosecute the criminal facilitation of tax evasion....more

Get Ready for the Countdown: Final Delaware Unclaimed Property Regulations Published

by McDermott Will & Emery on

On October 1, 2017, the Delaware Department of Finance published final regulations in the Register of Regulations repealing its former unclaimed property regulations and promulgating a new reporting and examination manual. ...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Uber’s Board of Directors has officially voted to realign the power balance at the company, reducing the clout of ousted CEO Travis Kalanick, and setting the stage for a stock sale to SoftBank. Oh yeah, and prepping for that...more

Treasury To Repeal/Revise 8 Burdensome Regs

As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more

New Registered Form Regs Proposed

by Morgan Lewis on

The IRS has proposed new regulations that would amend the definition of a “registration-required obligation” to broaden the scope of the types of arrangements that constitute pass-through certificates that generate portfolio...more

Hong Kong releases Consultation Report on Measures to Counter Base Erosion and Profit Shifting: key topics

by DLA Piper on

The Hong Kong government, represented by the Financial Services and the Treasury Bureau (FSTB) and the Inland Revenue Department (IRD), has released its Consultation Report on Measures to Counter Base Erosion and Profit...more

The New Partnership Audit Rules Are Here: Are You Ready? - Construction and Procurement Law News, Q3 2017

The January 1, 2018 effective date of the new federal partnership audit rules is almost here, and we encourage all entities taxed as partnerships to consider addressing the issues posed by these new rules as soon as possible....more

401(k)/403(b) Loan Borrowers – Check Your Paystubs!

by Foley & Lardner LLP on

A recent tax court case, Louelia Salomon Frias, v. Commissioner, TC Memo 2017-139, illustrates why it is good practice to verify that employee loan repayments have been timely deducted. Plan Loan Requirements. An employer...more

New guidance to register as “privileged” domestic or foreign investment fund under German investment taxation law

by Dechert LLP on

Pursuant to the new German investment tax act (GITA) that will take effect of 1 January 2018, domestic and foreign resident investment funds may become subject to German corporate income tax with various German source income...more

Protocol Amending the Mexico–Belgium Tax Treaty Published

by Jones Day on

On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion ("Tax Treaty") between Belgium and Mexico was published in Mexico's Official Journal...more

Bond-Financed Hospitals Must Apply New IRS Rules to Service Contracts

by McDermott Will & Emery on

After nearly two decades of restructuring service agreements to comply with Internal Revenue Service safe harbors, hospitals and other 501(c)(3) organizations are now subject to a new set of guidance and a single safe harbor...more

Debt Dialogue: August 2017 - The IRS Withdraws Proposed ‘Net Value’ Regulations

The IRS announced in July that it has withdrawn proposed regulations (the net value regulations) that provided guidance regarding corporate formations, reorganizations and liquidations of insolvent corporations. Those...more

Grecian Magnesite Mining: Impact on Investments by Non-US Investors in US Funds

by Morgan Lewis on

US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more

IRS Issues Guidance on RIC and REIT Stock Distributions

by Morgan Lewis on

The IRS has issued Revenue Procedure 2017-45, which provides that certain distributions of stock by a publicly offered RIC or publicly offered REIT made pursuant to a “cash or stock election” will be treated as a taxable...more

McDermott International Legal Highlights - August 2017

by McDermott Will & Emery on

Privacy Shield Implementation and How-To Kit from McDermott Will & Emery - Japanese companies may have European branches or subsidiaries that send personal data to the US or that may be accessed by entities in the US,...more

Not a Token Gesture: Compensating Service Providers with Virtual Property

by Morrison & Foerster LLP on

Questions surrounding the use of virtual currencies and other digital tokens (“tokens”) as compensation came to the forefront last month following formal guidance from the U.S. Securities and Exchange Commission (“SEC”) on...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tunisia

1. What role does the government of Tunisia play in approving and regulating foreign direct investment? The Tunisian government places a priority on attracting foreign direct investment. The Tunisian government...more

Tax Talk: Volume 10, Issue 2

by Morrison & Foerster LLP on

EDITOR’S NOTE - With the failure of health care legislation to “repeal and replace” the Affordable Care Act, eyes in Washington, D.C. are now turning to tax reform. Since Congress plans to take August off, any real tax...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tanzania

1 .What role does the government of the United Republic of Tanzania play in approving and regulating foreign direct investment? The government plays an active role in approving and regulating foreign direct investment....more

Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest

by McDermott Will & Emery on

In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more

The Distinction Between Partnership Debt and Partnership Equity

by White & Case LLP on

Insights and strategies in a rapidly changing area for taxpayers who want to be characterized as partners for tax purposes but want an investment that economically is very close to debt. Much ink has been spilled on the...more

AFRICA - A Legal Guide for Business Investment and Expansion: Nigeria

1 .What role does the government of nigeria play in approving and regulating foreign direct investment? Due to the economic benefits that accompany Foreign Direct Investment (FDI), the Nigerian government strives to...more

Securitisation in Poland: Legal and tax aspects

by Hogan Lovells on

Securitisation transactions have been receiving increased attention as attractive alternatives for Polish companies, especially those who can derive large pools of receivables from the debtors which are consumers or...more

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