Capital Gains

News & Analysis as of

Early Stage Investment Tax Incentives Bill Introduced

As an update to our Legal Insight of December 2015 'New Tax Incentives for Early Stage Investment', on 16 March 2016 the Turnbull Government introduced legislation providing significant tax incentives to promote local and...more

Federal Tax Advisory: Mark to Market

In January 2016, the Sixth Circuit reversed the Tax Court and ruled for the taxpayer in Wright v. Commissioner, 809 F. 3d 877 (6th Cir. 2016). If the IRS agrees, the ruling means that foreign currency contracts that are...more

U.S. PFIC Taxation Exemption to be Narrowed?

The last 15 years have seen the advent of a new reinsurance platform, where hedge funds have sponsored non-U.S. reinsurers, who in turn invest their capital in the sponsoring hedge funds. While there are business rationales...more

Incorporating a Partnership to Take Advantage of the Qualified Small Business Stock Rules (Update)

This is an update to a 2013 Legal Alert by Bahar Schippel and Bill Kastin titled: Excluding 100% of Gain From the Sale of Qualified Small Business Stock Acquired in 2013. Among the tax breaks included under the...more

UK Budget Residential Property Alert - March 2016

The Chancellor’s budget last week has been largely viewed as a business-friendly budget but it also contained some surprise announcements particularly for those who invest in, acquire and develop both residential and...more

UK Budget 2016: Tax implications for the private equity sector

The private equity sector was a net loser from last week’s Budget, with the proposed restrictions on interest deductibility and a lifetime limit on employee shareholder schemes. The extension of entrepreneurs’ relief is...more

UK Budget 2016: Employment tax

In the UK Budget 2016, the Chancellor made a number of announcements in relation to employment-related taxes. The following are some of the more interesting matters....more

Tax Announcements in the UK’s Budget 2016

The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our...more

UK Tax Measures—Spring 2016 Budget

The spring budget includes a number of announcements that relate to taxation, the most significant of which is a “roadmap” for UK corporate taxation through 2020....more

German Cum/Ex-Trades: Enhanced Risks and Industry-Wide Challenges

The German and international financial industries and their advisors have come under new pressure to investigate so-called 'cum/ex' trades conducted between 2000 and 2012. For many years, tax authorities and criminal...more

Real Property and Equities Transactions: Withholding is Now the First Port of Call

At present, capital gains and capital losses made by foreign residents are disregarded unless the asset being disposed of is taxable Australian real property (TARP). To ensure that foreign residents actually pay tax on...more

Obama's Budget Proposals Expand Application of Net Investment Income Tax and Address Carried Interest

On February 9th, President Obama released his Budget Proposals for 2017 (the "Budget Proposals"). The Budget Proposals include the following proposals that may affect private investment fund managers...more

European M+A News, Winter 2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

Tax Advantages for Angel Investors

Angel investors should be excited about recent legislative changes that are likely to improve the overall after-tax returns on their investment portfolios. As a result of the Protecting Americans from Tax Hikes Act (PATH),...more

Draft UK Income-based Carried Interest Legislation Published

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

Trusts and taxes - Understanding how one affects the other can benefit your estate plan

Trusts typically are a main component of an estate plan. But many may not know how higher taxes can impact a trust’s overall effectiveness. This article explains how the current tax environment affects trust planning....more

Tax Law Changes Favorable to Venture Capital and Private Equity Investors

The “Protecting Americans from Tax Hikes” (PATH) Act was recently signed into law, and two provisions in particular benefit venture capital, private equity, and other investors owning or planning to purchase a corporation....more

Tax Exclusions for Sale of Stock Issued by Qualified Small Business Corporations Becomes Permanent — At Least Temporarily

Over the past several years, Congress has sought to incentivize investment in small businesses by allowing taxpayers to exclude gains in certain small business stock sales. Gradually, Congress continued to increase these...more

The Built-In Gains Tax - S Corporations Are Gaining Ground

Many business owners are aware that, if a business is operated through a C corporation, the corporation pays tax on the profits and, when the profits are distributed to the shareholders in the form of dividends, the...more

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

Excluding Your Gains on Small Business Investments

2016 promises to be another very good year to invest in start-ups because of the extension of significant tax breaks for investors who invest in early stage companies. Investors who invest in small businesses can exclude...more

Real Estate Developers Pay Attention: Preserving Capital Gains Revisited by Tax Court

In Fargo v. Commissioner, TC Memo. 2015-96, the Tax Court reminded taxpayers and practitioners alike that a single sale can result in dealer treatment and, perhaps even more importantly, that: the taxpayer bears the burden of...more

Recent Legislation Permanently Extends Important Tax Planning Opportunity for Investors in Small Businesses

Legislation signed by President Obama on December 18, 2015, makes permanent a U.S. federal income tax exclusion from gross income of 100 percent of the gain recognized by non-corporate taxpayers on the sale or exchange of...more

U.S. Pre-Immigration Tax Planning

The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

Capital Gains Tax Exclusion for Certain New Investments in Small Businesses Made Permanent

President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) on December 18, 2015. Among other provisions, the PATH Act provides that the 100 percent exclusion from gross income of...more

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