Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
Selling Privately Held Businesses – Interview with Stephen Gulotta, Managing Member, Mintz Levin's New York Office
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk
Hot Topics for Waste-to-Energy Investors and Developers
Monitor Thy Drink: Alcohol Import Regulations Under the TTB (Alcohol and Tobacco Tax and Trade Bureau)
Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More
The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate Insights
Will The Debt Ceiling Standoff End Up In Court?
Corporate Law Report - Office Party Holiday Risks, Human Trafficking, the Fiscal Cliff, More
Micah Green on U.S. Fiscal Policy
How Do We Pay For Lower Corp Tax Rates?
Polsinelli Shughart Election Analysis and Legal Insight
Why choose Bennett Jones for your Canadian Cross-Border Income Trust (CBIT)?
What are the tax benefits of a Canadian Cross-Border Income Trust (CBIT)?
Why choose Canada for a Cross-Border Income Trust (CBIT)?
What is a Canadian Cross-Border Income Trust (CBIT)?
Bill on Bankruptcy: Solyndra, Lehman, MF Global, ATP Oil, LSP Energy, Want Ads
Should you Opt-Out of the Voluntary Disclosure Program?
Weekly Brief: CFPB, Legal Fees & Hashtag Hijackers
Cost of Voluntry Asset Disclosure Program
Protecting domestic revenue is just one of several reasons why G-20 nations are cracking down on tax havens. Other reasons include their desire to track the international flow of funds used for terrorist activity or money...more
On December 10, the UK House of Lords EU Sub-Committee on Economic and Financial Affairs published a follow-up report to its March 2012 report on the European Commission’s proposals for a financial transaction tax (FTT)....more
On December 13, 2013, the Fourth Circuit Court of Appeals in United States v. Under Seal, 2013 U.S. App. LEXIS 24785 (4th Cir. Va. Dec. 13, 2013), held that the required records doctrine applies when the government subpoenas...more
On December 5, 2013, the Internal Revenue Service (“IRS”) finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid...more
As part of 2010 legislation, Congress enacted section 871(m) of the Internal Revenue Code, which provides that payments made to foreign persons under specified notional principal contracts (“Specified NPCs”), securities...more
The deadline imposed by the Department of Justice (DOJ) for approximately 300 Swiss banks to come forward and request non-prosecution agreements expires December 16, 2013. In order to be eligible for a non-prosecution...more
Los Angeles Businessman, David Raminfard, pleaded guilty on November 4th, 2013 in the Federal District Court in Los Angeles to conspiring to defraud the United States, the Justice Department and Internal Revenue...more
La nozione di "abuso del diritto" in materia tributaria ha origine giurisprudenziale ed è definita come la messa in atto di tutte quelle operazioni imprenditoriali aventi l'obiettivo principale, quando non esclusivo, di...more
OSC to hold derivatives reporting seminar.
The Ontario Securities Commission announced that it will hold a seminar on January 15, 2014, on the reporting requirements under the new Derivatives Trade Repositories and...more
The IRS has published for comment two draft revenue procedures that change the existing process for US taxpayers requesting Competent Authority relief under the Mutual Agreement Procedures (MAP) and other provisions of US...more
CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT -
The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement.
The IGA is the first step in bring the Cayman fund industry...more
In recent months, the Australian federal Treasury has come under intense pressure from local retailers and state treasures to extend the Australian goods and services tax (GST) to overseas-purchased goods and services. On 27...more
Miriam Fisher, global Co-chair of the firm's Tax Controversy Practice, focuses her practice on federal tax controversy and litigation, including complex civil and criminal tax matters. Fisher spoke at the November 6, 2013...more
Cayman Islands signed a "Model 1" intergovernmental agreement on FATCA ("IGA"). The United States considers this IGA already to be in effect, despite the need for implementing measures in the Cayman Islands. This IGA is the...more
On November 29, the United States signed intergovernmental agreements with the Cayman Islands and Costa Rica to implement the Foreign Account Tax Compliance Act (FATCA). ...more
Canadians’ interest in acquiring U.S. real property for personal use remains strong. Without proper planning, however, that acquisition will expose the Canadian purchaser to U.S. estate tax on the fair market value of the...more
On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more
From April 2015, nonresidents will have to pay capital gains tax (CGT) on gains made from residential property sales in the United Kingdom, George Osborne announced today....more
The US Department of the Treasury recently announced that the United States has signed a “Model 1” intergovernmental agreement (an “IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”) with the Cayman...more
In this presentation:
- Form of foreign operations
- Foreign tax treatment of the foreign operations
- U.S. tax treatment of the foreign operations
- VAT/GST issues
- Employee and...more
From November 19 through 22, 2013, Senator Max Baucus, Chairman of the Senate Finance Committee (the "Committee"), released three staff discussion drafts that propose sweeping changes to the federal rules regarding...more
We recently reported on a case out of New York State, which dealt with the question of sales tax liability in the case of online sales. That decision (in Overstock.com v. New York Taxation Dept. and the companion case of...more
The German Federal States on 29 November 2013 approved the bill for the adjustment of the German Investment Tax Act (see also DechertOnPoint: German Investment Tax Act for Alternative Investment Funds) as adopted by the...more
You know what’s better than earning portfolio interest? Nothing. OK, that may be an overstatement. But for non-U.S. lenders looking to earn a return on their U.S.-based investments, with respect to paying U.S. taxes, that’s...more
The European Union (EU) has recently turned its attention to the thriving European digital economy. In two key areas, data protection and tax, the EU seeks to increase levels of regulation and impose new...more