Executive Compensation Packages – Interview with David Lagasse, Member, Mintz Levin
The Belgian Parliament has adopted a Program Law containing a wide array of fiscal measures. The most salient of these measures are (i) the introduction of a transparency tax regime for physical and legal persons subject to...more
There have been a number of changes to EU laws recently that have had, or will have, a direct impact on your clients who have connections with France. There are six stand-out issues that are worth careful and immediate...more
Yesterday, Senators Franken, Warren, Baldwin and Whitehouse sent Treasury Secretary Lew a letter regarding management fee waiver arrangements.
What is a management fee waiver arrangement? It is where a fund manager...more
It may be a common misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and then as a non-U.S. taxpayer make gifts or pass their estate to...more
Corporate America just can't spend its hoarded piles of cash savings fast enough. Climbing out of the deep hole of the most recent recession, big corporate America is now fast and furiously looking for ways to spend its cash...more
Marvin sold his principal residence for $1.4 million on an installment basis. He reported current gain of $657,796, and excluded $500,000 of that gain from income under Code Section 121 as a sale of a principal residence. The...more
WHAT ROLE WILL THE GOVERNMENT OF THE PHILIPPINES PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
The following Philippine government agencies are involved in approving and/or regulating foreign direct...more
The UK tax obligations of an individual depend in large part on the individual’s "domicile" under generally applicable English common law principles. The citizenship of an individual is irrelevant under the UK tax system. The...more
Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more
I. Overview -
On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more
On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more
On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more
On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"), which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of 1986 (the "Code") to...more
Because of the increases to the income tax rates and the reduction in the estate tax rates in recent years, anyone holding appreciated assets in a grantor trust should consider exchanging high-basis assets that have less...more
The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015.
The Draft Bill contains significant changes to the German tax...more
Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more
On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more
First it was three years, now it’s three months. The Senate’s attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August...more
In the recent Summer Budget, the Chancellor announced that with immediate effect, there would be changes to the way that carried interest is taxed. In technical terms, the “base cost shift” which enabled an investment manager...more
In Zhang v. Canada (A.G.) (2015 BSCS 1256), the British Columbia Supreme Court refused to grant rectification of a transaction in respect of which the taxpayers had no common intention to avoid capital gains tax on a share...more
Following up on my post from last week, presidential candidate Hillary Clinton has now provided more specific information on her proposed capital gains rates hike.
For high income filers (couples making at least $465,000...more
On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more
I did not grow up watching much TV, or at least TV programming in English, growing up in the Panama Canal Zone. The Military’s AFRTS did not come on the air each day until around 4;30 in the afternoon. In the...more
The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies.
In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more
As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...more
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