Corporate Taxes Capital Gains

News & Analysis as of

Basic Tax Issues in Mergers and Acquisitions

Mergers and acquisitions ("M&A") are complex, multilayered transactions with multiple moving parts and a healthy dose of negotiation. There are, however, common tax implications at play in most transactions of which...more

Global Tax News: Belgium Adopts New Fiscal Measures

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

Six Recommendations For Clients With Connections to France

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

Successful Strategies for Doing Business in Asia: Philippines

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

German Investment Taxation – Reform Ahead

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

The Upcoming Implementation of the Italian Patent Box Regime

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

New Stock Identification Requirements for New York Corporate Tax Exemption

Effective for tax years beginning on or after January 1, 2015, pursuant to legislation enacted last year, income from "investment capital" is exempt from New York State franchise tax for corporate taxpayers otherwise subject...more

The UK Summer Budget - Private Equity and Investment Management

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

UK Summer Budget 2015

On Wednesday, 8 July 2015, George Osborne delivered the UK Summer Budget. The first Budget of the new Conservative government (and the second Budget of 2015), the Summer Budget is wide-ranging in scope and potentially...more

Inside the New York Budget Bill: Department Issues Guidance Regarding Investment Capital Identification Procedures

On July 7, 2015, the New York Department of Taxation and Finance issued guidance (TSB-M-15(4)C, (5)I, Investment Capital Identification Requirements for Article 9-A Taxpayers) on the identification procedures for investment...more

High Net Worth Family Tax Report, Vol. 10, No. 1

Recent Case Illustrates Importance of Keeping Legal Entities in Good Standing - A recent United States Tax Court case illustrates the importance of keeping legal entities in good standing. In Medical Weight Control...more

Switzerland introduces corporate tax reform III aiming to maintain its global competitiveness: 6 key points

Anticipating ongoing pressure from the European Union and the OECD, Switzerland has launched a draft corporate tax reform, called CTR III, focusing on increasing the competitiveness of Switzerland as a global corporate...more

Ship on course but choppy waters abound! UK Budget 2015: 10 key measures impacting business

Before the Budget was announced, there was natural apprehension that, given the impending general election, the Chancellor would pander to the electorate and sail off course from this Government’s carefully navigated path...more

1031 exchange: a business strategy to defer capital gains tax, P.2

In our last post, we began speaking about the potential for businesses to take advantage of tax law to defer capital gains tax on business property they want to relinquish. One important thing to point out, though, is that...more

Tax Reform and the Timber Industry

This alert provides an overview of various timber tax issues in play as part of the tax reform debate. The alert is drawn from several sources, including former House Ways and Means Committee Chairman David Camp’s tax reform...more

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more

Global Tax News - January 2015

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

International Tax News - December 2014

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS - The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015. The government has published...more

Taxation Of Copyright Sales: Ordinary Income Or Capital Gain?

Tax day presents several interesting questions for copyright holders, not the least of which is how the Internal Revenue Service (IRS) will treat income from the sale or exclusive license of a copyright. If a copyright is a...more

PEA PME-ETI: An Enhanced Version of the French PEA of Interest for EU Asset Managers

A new French tax law, effective since the beginning of this year, has generated much excitement by creating an enhanced favorable tax regime – the PEA PME-ETI – for individual investors. The new regime is similar to the Plan...more

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

Proposed Carried Interest Legislation Takes A Different Approach

On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more

New Proposed Partnership Liability Allocation Regulations May Trigger Gains for Partners

On January 29, 2014, the U.S. Department of the Treasury and the Internal Revenue Service issued far-reaching and extremely taxpayer-adverse proposed regulations dealing with the allocation of partnership recourse and...more

Domestic double taxation relief applicable to capital gains derived by EU resident entities on disposal of shares in Spanish...

Following the non-discrimination principle, in response to an appeal dated 25 Octobe the Spanish Supreme Court has applied a tax credit to avoid double taxation, provided in the Corporate Income Tax Law for Spanish resident...more

No 15% Qualified Dividend Rate For CFC Inclusion

Back in 2011, we reviewed a Tax Court case that determined that income inclusion under the controlled foreign corporation (CFC) rules, while taxed like a dividend at ordinary income rates, could not qualify for the lower 15%...more

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