Withholding Tax

News & Analysis as of

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Private Placements and the Qualifying Private Placement Exemption

The new exemption from UK withholding tax will affect certain debt finance arrangements and the issuance of debt securities between foreign lenders or investors and UK corporate borrowers or issuers that operate in private...more

Update On The Exemption For Non-Residents From Payroll Withholding

The Canada Revenue Agency (“CRA”) recently introduced a program to ease the administrative burden associated with Canadian withholding on the salary, wages, or other remuneration paid to non-resident employees performing...more

Luxembourg tax reform 2017: key elements released

The Luxembourg government announced yesterday the key elements of a tax reform that should apply as from fiscal year 2017. Companies will generally benefit from a reduced corporate income tax rate, whilst minimum net wealth...more

2016 Federal Budget – Selected Tax Measures

On March 22, 2016, the Minister of Finance tabled Canada’s 2016 Federal Budget (the 2016 Budget). This was the first budget presented by the newly-elected Liberal government, which won a strong majority in the fall 2015...more

UK Budget 2016 – Key Tax Measures

The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more

Southeast State & Local Tax: Important Developments - March 2016

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast....more

UK Tax Measures—Spring 2016 Budget

The spring budget includes a number of announcements that relate to taxation, the most significant of which is a “roadmap” for UK corporate taxation through 2020....more

Committee Report: New Tax System for Managed Investment Trusts

On 10 March 2016, the Senate Economics Legislation Committee published the Report on the proposed legislation which will introduce a new system for taxing attribution managed investment trusts (AMITs). Committee's Views on...more

Private Placement Exemption: New UK withholding tax exemption for private placements

The new rules at a glance - Broadly, from 1 January 2016, there will be no UK withholding tax on interest payments on a loan/security which meets all of the requirements below: - not listed on a recognised stock...more

Real Property and Equities Transactions: Withholding is Now the First Port of Call

At present, capital gains and capital losses made by foreign residents are disregarded unless the asset being disposed of is taxable Australian real property (TARP). To ensure that foreign residents actually pay tax on...more

New UK Withholding Tax Exemption For Qualifying Private Placements

On 1 January 2016, a new exemption from UK withholding tax for interest paid on “qualifying private placements” came into force. The conditions to the new exemption focus on various attributes that HMRC consider to be...more

West Coast Real Estate Update: Feb. 2016 #4

ASTM Updates Property Condition Assessments Standard - The American Society for Testing and Materials (ASTM) published at the end of 2015 the latest version of the Standard Guide for Property Condition Assessments:...more

FIRPTA Tax Withholding Set to Increase Effective February 16, 2016

Beginning on February 16 of this year, the rate of tax withholding required by the Foreign Investment in Real Property Tax Act (FIRPTA) will increase from 10% to 15%. FIRPTA imposes federal tax on the sale of an interest in...more

PATH Act Amends FIRPTA

Congress enacted the Foreign Investment in Real Property Tax Act (FIRPTA) in 1980 to impose U.S. income tax on certain foreign persons that invest in United States real property interests (USRPI). The FIRPTA tax is collected...more

European M+A News, Winter 2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

New FIRPTA Reform Creates PATH to Potential Benefits for Existing REITs and Foreign Investors in the United States

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Among other changes, the PATH Act significantly modifies provisions of the Internal Revenue Code of...more

New FIRPTA Changes Provide Significant Opportunities, But No Panacea for Encouraging Non-U.S. Investment in U.S. Real Estate

Under FIRPTA, a non-U.S. person’s gain from the sale of U.S. real property interests is treated as income that is effectively connected with a U.S. trade or business (“ECI”), and therefore, is subject to U.S. federal income...more

FIRPTA Withholding Tax Rate to Increase 15 Percent on February 2016

On December 18, 2015, the Protecting Americans from Tax Hikes Act (the Act) was signed into law. Among other items, the Act materially amends the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) to increase the...more

Qualifying Private Placement Exemption

The qualifying private placement exemption, which became available on 1 January 2016, makes interest on privately placed notes and/or bilateral loans exempt from United Kingdom withholding tax in certain circumstances where...more

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act,” Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...more

Permanent U.S. Withholding Tax Rules for Non-US Investors in RICs – A New Distribution Opportunity

U.S.-registered investment companies (“RICs”) historically have had limited success attracting investments from non-U.S. investors, in large part due to U.S. withholding taxes on fund distributions. This has allowed funds...more

New Withholding Tax Exemption for Private Placements in the UK

Interest paid by UK companies is generally subject to withholding tax at 20%. Although various exemptions apply, most notably in respect of interest payments to banks and other UK companies, and in respect of securities...more

New year, new exemption: The UK withholding tax exemption for privately placed debt

Just over a year since the Chancellor of the UK Exchequer George Osborne announced in his Autumn Statement 2014 the introduction of a UK withholding tax exemption for interest paid under private placements (a form of unlisted...more

98 Results
|
View per page
Page: of 4
JD Supra Readers' Choice 2016 Awards

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×