On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more
The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more
The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more
Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more
Before the Budget was announced, there was natural apprehension that, given the impending general election, the Chancellor would pander to the electorate and sail off course from this Government’s carefully navigated path...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
Colombia has issued its list of tax havens – an act that will negatively impact the tax effects of doing business in Colombia from or through any of these tax haven jurisdictions.
The Tax Havens list was issued under...more
On September 26, 2013, the Canadian Tax Foundation Young Practitioners Group (Toronto) convened a panel discussion titled “GAAR at 25: Lessons Learned & Current Challenges” on the General Anti-Avoidance Rule (“GAAR”) in...more
In July 2013, the Stamp Duty Land Tax (SDLT) case of Project Blue Ltd v. HM Revenue & Customs, concerning the high-profile development of Chelsea Barracks, was the first real test of the SDLT’s broad anti-avoidance rule...more
California's Legislature responded to the residential foreclosure crisis by, among other things, enacting new statutes aimed at clarifying the rights of borrowers facing foreclosure and imposing new restrictions on...more
Originally published in CCH Canadian Ltd, February 7. 2013.
In This Issue:
- Subsection 56.4(7)— The “Realization of Goodwill Amount” and “Disposition of Property” Exceptions
- Areas of...more
Welcome to the Winter edition of Real World from Dechert’s London Finance and Real Estate Group, keeping you up to date with recent developments in real estate law and practice.
In this issue:
- An A-Z for 2013 – A...more
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