Corporate Taxes

News & Analysis as of

Private Equity Newsletter - Summer 2015 Edition: Indian Private Equity: Taxation and Trends

With a new government at India’s center and positive macroeconomic fundamentals working in its favor, the private equity industry is expected to invest more actively into India over the short to medium term. In the past year,...more

Taxpayer wins landmark decision regarding the UK tax treatment of US LLCs

Following the taxpayer’s victory in the recent Supreme Court decision of HMRC v Anson, UK resident members of Delaware LLCs may now be entitled to claim relief against their UK tax liabilities for US tax paid on their share...more

UK Supreme Court case of Anson v. HMRC [2015] UKSC 44

Delaware LLC held to be UK tax transparent - The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC as transparent for UK tax...more

Master Limited Partnership Parity Act Reintroduced To House And Senate

On June 24, 2015, the Master Limited Partnership Parity Act (S. 1656) was reintroduced in the House and the Senate. The legislation would provide investors in renewable energy projects with tax breaks that are currently...more

Is It All Now Transparent? UK Supreme Court Case on Delaware LLCs Leaves Open Questions on Entity Classification for UK Tax...

The UK Supreme Court delivered an unexpected final judgment on 1 July 2015 in the long-running case of Anson v Commissioners for Her Majesty’s Revenue & Customs [2015] UKSC 44. Reversing the decisions of the Upper Tribunal...more

Pennsylvania’s NOL Cap Litigation Moving Forward

In a Corporate Net Income Tax (“CNI”) appeal filed by Nextel Communications of the Mid-Atlantic, Inc. (“Nextel”), the Commonwealth Court will consider whether Pennsylvania’s statutory cap on net operating loss (“NOL”)...more

Brussels Regulatory Brief: June

This is the first in a series of monthly EU regulatory briefs - summarising key regulatory developments across a number of sectors in the EU. Antitrust and Competition - The European Commission launches an...more

Cross-Border Activities: Benefits of Filing “Protective” Returns

With the increasing focus by the Internal Revenue Service (IRS) on offshore activities, it is important to understand the tax return and information return filing obligations that may be associated with such activities....more

UAE Expected to Issue Draft Law on Corporate Tax and VAT

Although the United Arab Emirates (“UAE”) currently has Emirate level tax legislation in place, taxation has, to date, generally only applied to the oil and banking sectors. The last decade has seen the member states of the...more

Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

Partnership Rules Not Applicable to Determining Recourse vs Nonrecourse Status of Debt Outside of Subchapter K

Code Section 752 and its regulations provide extensive rules as to determining whether partnership debt is recourse or nonrecourse. Such determinations are relevant for basis determination purposes under Subchapter K (the...more

Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

Amended Return May Not Serve as Timely Refund Claim

Filing an amended tax return does not negate the need to file a timely petition for refund with the Pennsylvania Department of Revenue’s Board of Appeals. In a case decided in June, Quest Diagnostics Venture, LLC v....more

The Increased Cost of Tax (Non) Compliance and the New Trade Preferences Extension Act

On June 29, 2015, President Obama signed into law the Trade Preferences Extension Act of 2015. Neatly tucked away in the “Offsets” provision of the Act are sizeable increases in the dollar amounts of the penalties under...more

The China State Administration of Taxation releases working procedures for indirect transfer rules

In early February, the China State Administration of Taxation (SAT) issued Notice 71. This Notice superseded the provisions in relation to indirect share transfers under the well-known Circular 6982 and has become the key tax...more

Australian Tax Alert: Investment Manager Regime (IMR) – Bill To Implement Element 3 Is Now Law

Tax and Superannuation Laws Amendment (2015 Measures No. 1) Bill 2015 (the Bill), containing the third element of the IMR, has been passed by the Australian Parliament and received Royal Assent on Thursday 25 June 2015. This...more

Tax Review - June 2015

In This Issue: - Compensation for Uncollectible Debts Deprives Taxpayers of Their Eligibility to Benefit from VAT Relief for Bad Debts - Polish Definition of The First Occupation Inconsistent with the VAT...more

Tax Newsletter - March/April 2015 (China & Hong Kong)

In This Issue: The People's Republic of China: - China Tightens Tax Control Over Cross-Border Intercompany Payments - China Provides Further EIT Incentives For Integrated Circuit Industry - Expansion of...more

Corporate E-Note - June 2015

In this Issue: - IRS Issues Guidance on Portability: The IRS recently issued final regulations that provide guidance on the federal estate and gift tax applicable exclusion amount, in general, as well as the...more

NC Legislative Update for June 2015 #4

This Week - This week at the General Assembly was relatively dull compared to the last few weeks. The House Finance Committee used two meetings, Tuesday and Thursday, to review and discuss the tax package portion of the...more

Under the Dome: Inside the Maine State House

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Legislature Plans Long Day - Early this past Wednesday morning, the Maine House and Senate...more

Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...more

Publicly Traded Partnership Proposed Regulations

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

European Commission Launches Action Plan to Review EU Corporate Tax Framework and Close Tax Loopholes

The European Commission’s Action Plan for Fair and Efficient Corporate Taxation in the EU sets out proposals aimed at making corporate taxation in the EU more transparent and efficient, by reforming a system which is seen as...more

24 Months Through the Crystal Ball: Emerging Trends in State and Local Taxation (Part II)

This is the second of two articles guiding taxpayers through the next 24 months of state taxation’s turbulent waters. In this article, we address three additional significant trends. Corporate Income Taxation: Heat and...more

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