Capital Gains, Holding Companies

UK Asset Holding Companies: What Does the Future Hold?

Cadwalader, Wickersham & Taft LLP on 3/1/2021

The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more

Tax Court Affirms Treaty-Based Canadian Holding Structure

Bennett Jones LLP on 9/5/2018

The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more

Finance Bill 2019 – Proposed relaxation of entrepreneurs’ relief rules

Proskauer - Tax Talks on 7/13/2018

The proposed amendment to entrepreneurs’ relief (“ER”) in Finance Bill 2019 is designed to address one of the outstanding issues with the current law when dilution of a company results in the loss of ER. Under the current...more

Rolling Over Target Equity Into A PE Fund: Part II

Farrell Fritz, P.C. on 2/2/2017

Roll-Over: Tax Issue - Picking up on yesterday’s discussion, how can a PEF reconcile its preference to acquire a depreciable or amortizable basis for its target’s assets while, at the same time, affording the target’s...more

Rolling Over Target Equity Into A PE Fund: Part I

Farrell Fritz, P.C. on 2/1/2017

For many business owners, the final step of a successful career may be the sale of their business. At that point, the investment into which the owners have dedicated so much time, effort and money is liquidated, leaving them...more

Six Recommendations For Clients With Connections to France

McDermott Will & Emery on 9/28/2015

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