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The Spanish Supreme Court has released a relevant decision regarding the taxation in Spain of dividends collected by non resident Investment Funds from Spanish distributing entities in whose capital they participate....more
ALFI Notes the Commission’s Plans to Amend the UCITS and AIFM Directives - ALFI issued a press release pointing out that they believe that a wider scope for the clarification of marketing and pre-marketing would have been...more
International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more
After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more
A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more
In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more
The Organisation for Economic Co-operation and Development (OECD) published a revised discussion draft on 22 May 2015, in relation to Action 6 of the BEPS (Base Erosion and Profit Shifting) Action Plan (Action Plan 6), which...more