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Capital Gains International Tax Issues

Seyfarth Shaw LLP

Hong Kong’s Foreign-Sourced Income Exemption Regime (FSIE) Refined

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To bring Hong Kong’s Foreign-Sourced Income Exemption (FSIE) regime in line with the European Union’s updated guidance on FSIE regimes promulgated in December 2022, the Inland Revenue (Amendment) (Taxation on Foreign-sourced...more

McDermott Will & Emery

UK Labour Party's Statement on Non-Dom Tax Reforms

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Following the UK Government’s 6 March announcement of tax reforms for the current “non-dom” tax regimes, the opposition Labour party has begun to outline how its plans would differ if they win the next UK general election. In...more

Mayer Brown

Requalification des gains issus de Management Packages en salaires et interposition d'une holding personnelle : nécessité pour...

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La Cour administrative d'appel de Paris rejette la requête de l'administration fiscale tendant à la requalification en salaires de gains réalisés par la holding personnelle d’un dirigeant lors de la cession de titres acquis...more

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

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Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Stikeman Elliott LLP

Employee Ownership Trusts: Full Steam Ahead After Government’s Fall Economic Statement

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On November 21, 2023, the Government of Canada released its Fall Economic Statement. Among the measures included in the statement are improved tax incentives for Employee Ownership Trusts (“EOTs”)....more

Cadwalader, Wickersham & Taft LLP

Court of Justice Rules on UK Group Asset Transfer Rules

The UK tax legislation imposes an “exit tax charge” on the unrealised capital gains of a company which migrates from the UK. The exit of a taxpayer (or their assets) is generally the last point in which a taxing jurisdiction...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

BCLP

Delay to Luxembourg-UK treaty changes - impact on UK real estate

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Unexpectedly, it is likely the changes to the Luxembourg-UK double tax treaty will not be effective until 2024 at the earliest. Where that is the case, some Luxembourg investors in UK property rich entities will have another...more

A&O Shearman

The new Luxembourg/United-Kingdom tax treaty has been signed.

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More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more

Goodwin

The UK and Luxembourg Signed A New Double Tax Treaty

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On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more

ArentFox Schiff

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

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The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

Hogan Lovells

Spain: Law 11/2021 implementing ATAD and other measures against fraud

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The Spanish Parliament has finally approved Law 11/2021, of 9 July, on measures to prevent and fight against tax fraud (“Law 11/2021”) which implements several aspects of Council Directive (EU) 2016/1164 of 12 July 2016...more

Cadwalader, Wickersham & Taft LLP

UK Asset Holding Companies: What Does the Future Hold?

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

Proskauer Rose LLP

UK Tax Round Up - January 2021

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UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more

Proskauer - Tax Talks

New OTS report recommends changes to UK’s capital gains tax regime

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The Office of Tax Simplification (OTS) has published its first report following its review of certain aspects of the UK’s capital gains tax regime requested by the Chancellor in July this year with the specific purpose of...more

White & Case LLP

German IP Withholding Tax

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On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more

Bennett Jones LLP

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

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On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more

Bennett Jones LLP

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

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On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more

Proskauer Rose LLP

UK Tax Round Up - April 2019

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UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more

Bennett Jones LLP

New Ratifications of the OECD's Multilateral Instrument Put Canadian Resource Holding Structures at Risk

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Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

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EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more

White & Case LLP

Belgian draft law ratifying the MLI: A new paradigm in international tax law

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On February 4th, 2019, the Belgian government released a draft law ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "Convention") and the...more

Holland & Knight LLP

Mexico Grants Tax Incentives on Capital Gains, Corporate Bond Interest

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A Presidential Decree by Mexico President Andrés Manuel López Obrador granting a new set of income tax incentives to capital gains and interests derived from corporate bonds (the Decree) became effective on Jan. 9, 2018. ...more

Proskauer - Tax Talks

UK Budget – Some Key Changes

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The UK Budget took place on 29th October. The Chancellor, Philip Hammond, took the opportunity to make a series of targeted changes to the UK’s tax system, some of which had already been announced, but several of which were...more

Troutman Pepper

IRS Withholding Tax Guidance Helpful, But Not Perfect

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As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests. ...more

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