Withholding Tax

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Wimpy’s Investment Strategy for Foreign Real Estate Investors - Real Estate Deferral Options for Foreign Investors beyond the 1031...

Overview - I did not grow up watching much TV, or at least TV programming in English, growing up in the Panama Canal Zone. The Military’s AFRTS did not come on the air each day until around 4;30 in the afternoon. In the...more

Corporate Resource Services, Inc. and Seven Affiliates File Chapter 11 Petitions As Part of Ongoing Wind Down

On July 23, 2015, Corporate Resource Services, Inc. and 7 affiliates filed voluntary chapter 11 petitions in the United States Bankruptcy Court for the District of Delaware. The cases are docketed as case no. 15-11546, and...more

California Employment Law Notes - July 2015

Employee's Inability To Work For A Particular Supervisor Does Not Constitute A "Disability" - Higgins-Williams v. Sutter Med. Found., 237 Cal. App. 4th 78 (2015) - Michaelin Higgins-Williams worked as a clinical...more

Foreign Resident Capital Gains Withholding Tax – Draft Legislation Released

On 6 November 2013, the Federal Government announced that it would introduce a 10% non-final withholding tax on the disposal of certain taxable Australian property by foreign residents. This measure aims to assist the...more

Tax Measures in the UK 2015 Summer Budget

The new tax announcements are designed to improve productivity and correct imbalances in the tax system. On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

California Appellate Court Holds Employer Must Withhold Taxes on Back Pay

On June 26, 2015, a California appellate court rendered a precedential opinion that should hopefully put to rest the issue of whether an employer must withhold taxes on settlements or judgments made to former employees in...more

Davidson v. Henkel — What’s Going On With Nonqualified Deferred Compensation Plans and FICA

In This Presentation: - Davidson v. Henkel Corp. - The Parties - NQ Plan - The Plan’s Tax Clauses - Davidson’s Pre-Retirement Counseling - 2011 Compliance Review and Letter - Henkel’s Tax...more

Tax Law

In This Chapter: Tax Law: Annual Survey of Wisconsin Law - - Case Law - Statutory Developments - Administrative Developments - Excerpt from Case Law: Individual and Fiduciary Income Tax...more

To Forgive, Divine: Tax Amnesty Program Signed Into Law

On Tuesday, April 27, 2015, Missouri Governor Jay Nixon signed House Bill 384, which creates a Tax Amnesty Program for taxes administered by the Missouri Department of Revenue. This includes state income taxes, franchise...more

Tax: Tax Considerations for Technology Licenses

The parties to licenses of technology should consider tax issues with such licenses. The following is a summary of some of the tax implications that may arise with regard to technology licenses....more

From Hiring To Firing: A Basic Guide To The Singapore Employment Law Life Cycle

In Singapore, we are restricted for regulatory reasons (as are most international/foreign registered law firms) from practising local law. This means that if a matter needs advice on any Singapore law issues we will arrange...more

Global Tax News - March 2015

Australia's Investment Management Regime reforms 30 MAR 2015 - Australia’s Investment Management Regime (IMR) reforms, initially proposed by the Australian Financial Centre Forum in the Johnson Report in 2009 and the...more

The Religious Freedom Restoration Act (RFRA) and Wage and Hour Law

Unless you are living under a rock, you are probably aware of the uproar in Indiana about the Religious Freedom Restoration Act that the state passed, triggering an incredible backlash inside and outside the state and a rush...more

Potential refund of Swedish withholding tax: opportunity for US RICs

In 2012, the Swedish Administrative Court of Appeal concluded that Sweden’s withholding tax rules are not compatible with EC law when Swedish withholding tax is levied on dividend payments made to a Luxembourg SICAV fund. ...more

Private placements: a new UK withholding tax exemption

The Finance (No.2) Bill 2015 contains provisions for an exemption from the obligation to deduct UK income tax from yearly interest paid on “qualifying private placements”. This measure was first announced on 3 December...more

UK budget 2015

Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more

Employers: Properly Administer Nonqualified Deferred Compensation Plans, or You May Be Held Liable to Participants for Adverse Tax...

An employer’s liability to retirees for “improper” FICA tax withholding illustrates the importance of diligent administration of nonqualified deferred compensation plans. In the recent case of Davidson v. Henkel Corp.,...more

Guide To Going Global: Global Equity Restricted Stock And Restricted Stock Units 2015

Welcome to the updated edition of DLA Piper’s Guide to Going Global – Global Equity, Restricted Stock and RSUs. GUIDE TO GOING GLOBAL SERIES - Many companies today aim to scale their businesses globally and into...more

Guide To Going Global: Global Equity Employee Stock Purchase Rights 2015

Welcome to the updated edition of DLA Piper’s Guide to Going Global – Global Equity, Employment Stock Purchase Rights. GUIDE TO GOING GLOBAL SERIES - Many companies today aim to scale their businesses globally...more

Australia: What is and is not a “royalty” for withholding tax purposes? Latest key court decision

By Jock McCormack, James Newnham, Matthew Cridland and Eddie Ahn Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal...more

Important royalty withholding tax decision

The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all...more

New UK Withholding Tax Exemption Set to Boost the UK Private Placement Market

On 4 December, George Osborne in his Autumn Statement, announced a new UK withholding tax exemption for interest payments on UK private placements. The announcement was followed by draft legislative clauses with the Finance...more

MoFo New York Tax Insights - Volume 5, Issue 5 - May 2014

In This Issue: - Two Combined Reporting Decisions Highlight Issues Involving “Permissive” Combined Reporting - New York State Corporate Tax Reform Legislation Enacted – What You Need to Know - Appellate Court...more

Court’s Ruling Holding Corporate Officer Responsible for Trust Fund Recovery Penalty Illustrates Risk of Personal Liability for...

A district court in the Northern District of California has held that the officer of a now-defunct corporation is personally responsible for the Trust Fund Recovery Penalty based upon the company’s failure to collect, account...more

LSTA Publishes Revised Documents Effective April 24, 2014

The Loan Syndications and Trading Association (LSTA) has released new forms of its primary trading documents, effective for trades entered into on or after April 24, 2014. The LSTA's updated forms are primarily...more

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