News & Analysis as of

Spain’s Basque Country extends participation exemption regime to capital gains on transfer of shares in Spanish companies

Spain’s autonomous Basque Country region has extended its participation exemption regime (applicable to foreign participations) to capital gains derived from the transfer of shares in Spanish companies (dividends were already...more

New Tax Increases Make Deferral of Compensation a (More) Valuable Benefit for Many Employees

This article describes how the new additional Medicare tax, tax on net investment income, higher marginal tax rates, and phase-out and reductions of personal exemptions and itemized deductions make the use of compensation...more

"Shares for Rights: Over-Sold or Under-Appreciated?"

In this article we consider some alternative approaches to the proposed U.K. status of “employee shareholders,” who receive capital gains tax-exempt shares in their employer (or its parent) in return for waiving certain...more

Editorial: Expatriating From U.S. To Puerto Rico May Make Sense For Some

The United States is one of only two countries in the world that taxes its citizens and residents on their worldwide income. Therefore, a U.S. taxpayer who earns only foreign-source income will be subject to U.S. federal...more

Expatriation Lite: Leaving The U.S. Tax System While Retaining Your Citizenship

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

Readjustment of Taxation of Free Floating Dividends and of Fiscal Unity – Current Legislative Procedures

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

Portability

Congress recently made permanent the “portability” of a predeceasing spouse’s unused estate tax exemption (currently, $5.25 million per spouse)....more

Budget Briefing 2013

The Honourable Jim Flaherty, Minister of Finance, tabled Budget 2013 today. In his Budget Speech, the Minister lauded Canada’s economic strength and achievements over the last seven years, while acknowledging that there are...more

Congress Extends the 100% Tax Exemption for Gain on Certain Qualified Small Business Stock, With Retroactive Effect, Through 2013

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “Act”). Among its provisions, the Act extends a tax benefit whereby capital gains from the sale or exchange of certain...more

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

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

The American Taxpayer Relief Act of 2012 and What It Means to You

On Jan. 2, 2013, President Obama signed the “American Taxpayer Relief Act of 2012” (the “Act”) which was passed by the House and Senate the previous day to avoid the so-called “fiscal cliff.” The Act prevents many of the tax...more

‘Fiscal Cliff’ Legislation Temporarily Extends Key Provisions for Businesses

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

Fiscal Cliff Tax Changes

On New Year’s Day 2013, the “American Taxpayer Relief Act of 2012” (the Act) was enacted to avoid the impact of automatic “fiscal cliff” tax increases. The Act, effective January 1, 2013, retains and makes permanent the...more

The American Taxpayer Relief Act of 2012: What It Means for You

In the final hour of January 1, 2013, Congress passed The American Taxpayer Relief Act of 2012 (the "Act"), which in part addressed the dramatic sunset of favorable federal estate, gift and generation-skipping tax exemption...more

14 Results
|
View per page
Page: of 1