Tax Finance & Banking Securities

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UK Budget 2015 - Private Equity

As widely expected today’s Budget did not involve any great surprises. It was full of statistics spanning the duration of this Parliament, electioneering and a recap of items previously announced in the Autumn Statement....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

Real Estate Gazette - Issue 19 (Global)

In This Issue: - INTERNATIONAL: Key Issues For Real Estate In The Implementation Of The AIFMD Across Europe - ASIA: Understanding Four Key Changes To The Hong Kong REIT Code -...more

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

EU Passes New Council Directive to Implement “EU-FATCA" - The Council Directive passed by the EU on 1 December 2014 implements the OECD’s Common Reporting Standard (CRS) in Europe. The Directive has to be implemented...more

Monthly Benefits Alert - February 2015

Health & Wellness Plans - Anthem Data Breach Requires Plan Sponsor Attention - On January 29, 2015, Anthem Inc., one of the largest managed health care companies in the country, disclosed that the sensitive...more

Tax Policy Update

NUMBER OF THE WEEK: $42,268. The projected average taxable income of all tax returns in 2015, according to the Joint Committee on Taxation’s Feb. 27 report on “Fairness and Tax Policy.” The report also projects that the top...more

Welcome Tax Measures Announced at the PDAC 2015 Convention

On Sunday March 1, 2015, the Honourable Joe Oliver, Federal Minister of Finance addressed the Prospectors & Developers Association of Canada (“PDAC”) at the annual PDAC Convention in Toronto and announced certain proposals...more

Insigh: Capital Markets: Tips for Taps

Following a successful bond issuance, an issuer may consider a “tap” issuance as a way to access further funding. White & Case offers some “Tips for Taps” for issuers and underwriters in accessing the capital markets...more

IRS Releases First Private Letter Ruling on Small Redemption Limitation

On October 21, 2013, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Final Treasury Regulations to provide relief under Section 382 for small redemptions. These regulations provide taxpayer...more

Fifth Circuit Holds that Loss on Abandoned Securities is Ordinary Loss

Wednesday, the Fifth Circuit issued its decision in Pilgrim’s Pride and held that a loss on abandoned securities is ordinary. The Fifth Circuit rejected the IRS’s argument that Section 1234A and Section 165(g) apply to treat...more

Hong Kong Government to Extend Existing Offshore Funds Tax Exemption to Private Equity Funds

The Hong Kong government has announced in its latest budget a planned extension of the existing offshore funds tax exemption to bring offshore private equity funds investing in or through Hong Kong, within its scope. The...more

Morrison & Foerster Quarterly News Tax Talk - Volume 7, No.4 January 2015

In This Issue: - Congress Passes Year-End Tax Extenders Bill - House Adopts New “Dynamic Scoring” Rule - Foreign Fund Engaged in Lending and Stock Distribution Not Protected by “Trading in Stock or Securities”...more

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

CSSF Reminder Regarding Nomination of Depositaries of Bearer Shares - The Luxembourg regulator for the financial services industry (CSSF) has issued a press release and a FAQ in relation to the immobilization of bearer...more

Control Transactions in the UK Mid-Market

In a number of transactions in the UK mid-market in which we have been involved recently, we have noted a departure from the traditional private equity buy-out model, whereby the sponsor acquires 100% of the target and...more

Senate Finance Committee Proposes FIRPTA Reform

Today was an important step in moving forward US tax reforms to encourage international investment in U.S. real estate.  The Senate Finance Committee passed 17 different tax bills for consideration by the entire Senate.  ...more

3 Developments Real Estate Fund Sponsors Should Know for 2015

Changes in fee terms as well as new guidance regarding GAAP consolidation and potential future tax developments can impact how fund sponsors structure and negotiate their investment vehicles. Despite a slight downturn in...more

"Unlocking Value Through REIT Spin-Offs"

Real estate investment trust (REIT) spin-offs provide a means for companies to unlock the value of their real estate. Due to current economic conditions, more companies in more business sectors are considering separating...more

OSC Expects REIT Distributions Disclosure to Yield More Information

In the current low interest rate environment, yield-hungry investors have been particularly attracted to real estate investment trusts (REITs), which, as tax-efficient, flow-through investment vehicles, aim to pay regular...more

Happy Valentine’s Day – Schedule 13G Filings Due This Year on February 17, 2015

Investors that own more than 5% of a public company’s securities and file under the exempt category (which includes most venture capital firms and other similar investors) are required to file their beneficial ownership...more

2015: A New Agenda for Europe

Every year, the European Commission (the Commission) adopts a plan of action for the next 12 months. The Work Programme for 2015 is the first one to be presented by the Juncker Commission. It translates into concrete actions...more

Section 83(b) - Paying a Little Now Might Save You a Lot Later

Great news!  You have been granted stock in a company. Bad news: that means you are going to owe taxes. If you were granted restricted stock in a company you will want to (quickly) think about filing a Section 83(b) election....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

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

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