Podcast: Cum-Ex Dividend Trade Investigations
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Venture Capital Trends: East Meets West – Lewis Geffen, Co-chair, Venture Capital Practice
What Individuals and Businesses Need to Know About the American Taxpayer Relief Act
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more
The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and...more
The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more
President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more
Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more
One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...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
In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more
Federal Ministry of Finance: If the capital gain is not taxable in Germany, the correspondent dividends are taxed. With its circular letter dated 26 July 2013, the Federal Ministry of Finance comments on the tax...more
As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more
Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more
After much contention,Congress passed the American Taxpayer Relief Act of 2012, and President Obama signed the legislation on January 2, 2013. The Act avoids automatic sunset provisions that were scheduled to take effect...more
With the American Taxpayer Relief Act of 2012 (the “ATRA ”) passed and the fiscal cliff safely averted, the time has come to turn your attention to your estate plan. What Did the ATRA Accomplish? The fiscal cliff...more
Now that a deal averting the fiscal cliff has finally been reached, many of the tax and planning issues that have been mired in uncertainty for the past two years (and even longer in some cases) may be resolved. Numerous tax...more
On January 2, President Barack Obama signed into law the American Taxpayer Relief Act of 2012, H.R. 8 (ATRA), preserving many of the key tax provisions passed during the George W. Bush presidency, which were scheduled to...more
2012 Tax Act - The American Taxpayer Relief Act of 2012 (the “Act”) was signed into law on January 1, 2013 to avert the tax law changes that were one part of the “fiscal cliff” facing our country’s economy (the other...more
Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more
Summary - President Obama on January 2, 2013 signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act extends certain tax rates, tax credits, and other provisions previously enacted by other tax...more
On January 1, 2013, Congress averted the fiscal cliff with the passage of the American Taxpayer Relief Act of 2012 (Act), which was enacted when President Obama signed the Act on January 2, 2013. The Act provides a welcome...more
On January 1, 2013, the Senate and House of Representatives passed the American Taxpayer Relief Act of 2012 (“ATRA”), signed into law by President Obama on January 2. ATRA averts the “fiscal cliff” by making permanent the...more
On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act), effective as of January 1, 2013. In general, the Act made permanent for most taxpayers the tax rate cuts first enacted...more
As part of legislation enacted in early 2013 to avert the so-called “fiscal cliff,” Congress temporarily extended several beneficial tax provisions for businesses, including the research credit, the active financing exception...more