News & Analysis as of

Anti-Avoidance

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

Australian Federal Budget 2017 - 2018

by DLA Piper on

The Australian Government introduces a new major bank levy, increases the costs for foreign owners of Australian real estate and extends Managed Investment Trust concessions to investment in Affordable Housing from 1 July...more

The Australian Government significantly expands ATO powers to fight multinational tax avoidance: Legislation introduced for 40 per...

by DLA Piper on

Introduction and overview - The Australian Government introduced legislation (DPT legislation) into Parliament on 9 February 2017 to implement a further component (second limb) of the United Kingdom–style diverted...more

Treasury Issues Final Regulations Under Section 956

by Alston & Bird on

On November 3, 2016, the Treasury issued final regulations (T.D. 9792) that set forth guidance on when a controlled foreign corporation (CFC) has a deemed repatriation under Section 956 in ...more

MoFo New York Tax Insights - Volume 7, Issue 8

by Morrison & Foerster LLP on

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

Tadjudin Sunny vs. Bank of America National Association - implied term of anti-avoidance

by DLA Piper on

In 2007, the Bank terminated an Analyst in its Distressed Debt Trading Group by payment in lieu of notice, following completion of a Performance Improvement Plan (PIP). She was not awarded any bonus on her departure. The...more

"Insights: Brexit"

On June 23, the UK electorate took the historic decision to leave the European Union, a process that has never been undertaken by any member state. While the vote itself does not trigger the process of exit from a legal...more

EU Council Agrees on Final Anti Tax Avoidance Directive

by Proskauer - Tax Talks on

We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

Private equity in Italy: market and regulatory overview

by Latham & Watkins LLP on

How do private equity funds typically obtain their funding? Private equity funds continued to have a diverse investor base in 2015. Although with a significant decrease from the 2014 figure of 68%, about 48% of the...more

Real News - Spring 2016

by DLA Piper on

Earlier this year, David Cameron fired the starting gun on whether Britain should continue its membership of the EU. As we all know, the potential effect of a Brexit is a topic which has divided the opinions not only of our...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

by Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

UK Taxation Update for Investment Managers

by Dechert LLP on

The shifting sands of the taxation landscape for investment managers continues apace. Just when you perceive an oasis of stability on the horizon, it is revealed to be a mirage by the announcement of yet further changes....more

The AGA GAGA SAGA or The Never-ending Story? - EMI Group Limited v. O&H Q1 Limited

by Dentons on

Like a Scandinavian drama, the AGA GAGA SAGA is compelling, dark, protracted and engaging. With each new episode there is an exciting twist as new characters contribute to the plot and the viewers try and work out what it all...more

UK Budget 2016: Corporate tax and business transactions

by DLA Piper on

This is a brief summary of some of the issues arising from the UK Budget 2016 which have an effect on corporate tax....more

UK Budget 2016 – Overview

by White & Case LLP on

The Chancellor has presented a packed March Budget bursting at its seams with measures impacting businesses and individuals alike... ..The first reference to tax in his statement was to "tax avoidance" and that tells...more

To submit or not to submit – questions of jurisdiction

by Reed Smith on

This appeal arose out of the litigation fallout from the Bernard Madoff Ponzi scheme. In the appeal, the Privy Council considered whether, at common law, an agreement to submit to jurisdiction must be express or whether it...more

Tax-efficient Pension Savings in the UK: Government Applies Further Restrictions

by Latham & Watkins LLP on

Employers may want to adjust compensation packages, and high-earners may want to revise their retirement savings strategies. In recent years, the UK government has reduced the lifetime and annual thresholds up to which...more

Draft UK Income-based Carried Interest Legislation Published

by Latham & Watkins LLP on

Proposed new UK rules will tax carried interest in certain funds as income, with only specified funds entitled to capital gains treatment - The UK government published draft legislation on 9 December 2015 amending the...more

International Tax Advisory: New IRS Notice Continues Attack on Inversions

by Alston & Bird on

There is no love lost between the U.S. Treasury and U.S. companies seeking offshore tax homes. Absent congressional action to stem the inversion tide, the Treasury and IRS are left to flex their regulatory and administrative...more

UK Autumn Statement 2015 – Key Tax Measures

The Chancellor of the Exchequer delivered his budgetary Autumn Statement on 25 November 2015. In this Client and Friends Alert we have outlined the key tax measures that we expect to be of interest to Cadwalader’s clients...more

UK 2015 Summer Finance Bill Update: Proposed Taxation Changes for Carried Interest and DIMF

by Proskauer Rose LLP on

Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF). The UK Government proposed...more

Global Private Equity Newsletter - Fall 2015 Edition: The Summer Budget – Changes to the UK Tax Treatment of Carried Interest

by Dechert LLP on

The Chancellor of the Exchequer’s recent Summer Budget and the related legislation introduced a series of unexpected tax changes along with the promise of further changes to come. Shortly after the Summer Budget was issued...more

Treasury and IRS Issue New Temporary Treasury Regulations

by McDermott Will & Emery on

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 UK Summer Budget - Private Equity and Investment Management

by Dechert LLP on

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

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