Income Taxes Capital Gains

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
News & Analysis as of

President Obama’s Administration Continues Its Quest to Limit the Ability to Defer Income Under IRC § 1031

As reported in my November 2014 blog post, President Obama’s administration wants to limit taxpayers’ ability to defer income under IRC § 1031. In response to former House Ways and Means Committee Chairman David Camp’s...more

Federal Tax Advisory: Mark to Market

In January 2016, the Sixth Circuit reversed the Tax Court and ruled for the taxpayer in Wright v. Commissioner, 809 F. 3d 877 (6th Cir. 2016). If the IRS agrees, the ruling means that foreign currency contracts that are...more

Tax Announcements in the UK’s Budget 2016

The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our...more

Trusts and taxes - Understanding how one affects the other can benefit your estate plan

Trusts typically are a main component of an estate plan. But many may not know how higher taxes can impact a trust’s overall effectiveness. This article explains how the current tax environment affects trust planning....more

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

U.S. Pre-Immigration Tax Planning

The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

Congress Permanently Extends Capital Gains Exclusion for Qualified Small Business Stock

Tax law change is good news for non-corporate investors. On December 18, 2015, President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) into law. The PATH Act retroactively renews and...more

Trust And Estate: Changes To UK Resident Non Dom Income Tax Laws Leads To Need To Establish A Resident Non Dom Income Tax Trust...

The UK tax obligations of an individual depend in large part on the individual’s "domicile" under generally applicable English common law principles. The citizenship of an individual is irrelevant under the UK tax system. The...more

IRS Issues Notice Announcing Intention to Require Gain Recognition on Certain Transfers of Property to Partnerships with Related...

I. Overview - On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

Did You Create a Grantor Trust? - Trust and Estates Update Vol. 2015, Issue 1

Because of the increases to the income tax rates and the reduction in the estate tax rates in recent years, anyone holding appreciated assets in a grantor trust should consider exchanging high-basis assets that have less...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

Changes in the UK Tax Treatment of Carried Interest

In the recent Summer Budget, the Chancellor announced that with immediate effect, there would be changes to the way that carried interest is taxed. In technical terms, the “base cost shift” which enabled an investment manager...more

Proposed Regulations Issued On Management Fee Waivers

On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more

Changes to Non-Domiciled Status Announced in The UK Summer Budget 2015

Following the United Kingdom’s General Election in May, George Osborne, Chancellor of the Exchequer, gave the new government’s first budget speech on 8 July 2015. In his speech, Mr Osborne announced some changes to the tax...more

Guide To Doing Business in New Zealand: Taxation (Updated)

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

No Theft Loss for Securities “Pump-and-Dump”

Pump-and-dump occurs when corporate officers or other shareholders fraudulently promote shares of a company and engage in fraudulent sales to increase the value of shares. This is injurious to other shareholders who suffer...more

Estate Planning Pitfall: Your IRA owns real estate

Most people invest their IRA funds in stocks, bonds and mutual funds. But others may opt for nontraditional investments, such as real estate, in the hope of boosting their returns. As this article details, when choosing to...more

Investment Funds Update – Asia: Legal and regulatory updates for the funds industry from the key jurisdictions in Asia: Mainland...

Capital gains tax (“CGT”) has been a key issue surrounding the investment by QFIIs and RQFIIs in the Mainland Chinese securities market. Mainland Chinese tax authorities have publicly decided to retrospectively collect CGT...more

Draft legislation released covering changes to the employee share scheme tax regime

The Australian Government has today introduced the draft Tax and Superannuation Laws Amendment (Employee Share Schemes) Bill 2015 containing measures designed to ease the tax impost for employee shares schemes, to make...more

Starting a Hedge Fund in 2015

Hedge funds are well into the transition from bastions of alternative investment to being accepted into the mainstream investment marketplace. It is now estimated that global hedge fund assets under management amount to in...more

Overview of the Taxation of Foreign Currency

In this Newsletter: - Determination of the Functional Currency and Definition of a “QBU” - Section 988 — Non Functional Currency Transactions - Section 986 — Translation Rules for Earnings and Profits and...more

Obama 2015 Tax Proposals

President Obama’s State of the Union address, delivered on January 20, 2015, proposed three significant changes to US federal tax law: (1) an increase from the current 20 percent rate to 28 percent for the top federal capital...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

China Tightens Individual Income Taxation On Capital Gains From Equity Transfer

China's State Administration of Taxation (SAT) recently promulgated the Public Announcement [2014] No. 67, Administrative Measures for Individual Income Tax on Income from Equity Transfers (for Trial Implementation) (Equity...more

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