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Withholding Tax

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

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The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Foley & Lardner LLP

Section 1446(f) Withholding and Private Fund Admissions and Withdrawals

Foley & Lardner LLP on

Withholding Under Code Sections 1446(a) and 1446(f) A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or...more

Baker Donelson

SALT Select Developments - July 2024

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Cadwalader, Wickersham & Taft LLP

Aftermath of YA Global: A Call for Procedural Clarity for Section 1446 Withholding Tax

The New York State Bar Association Tax Section (the “NYSBA”) has asked the government to provide guidance on the procedure for filing a protective return in respect of withholding tax in response to YA Global Investments, LP...more

Cadwalader, Wickersham & Taft LLP

IRS Kicks Substantial Equivalence Test Down the Road Again

On May 22, 2024, the IRS issued Notice 2024-44, which once again extends the phase-in for Section 871(m) withholding.  Broadly speaking, foreign persons may be subject to a 30% withholding tax under Section 871(m) on certain...more

Morgan Lewis

'FASTER" EU Council of Ministers Adopts Directive to Harmonize Withholding Tax Procedures

Morgan Lewis on

On May 14, 2024, ECOFIN agreed on the Directive on Faster and Safer Relief of Excess Withholding Taxes (so-called FASTER Directive) after numerous adjustments to the EU Commission's proposal for a directive from June last...more

Littler

Shift Work and Tax Relief in Belgium: The New Law Introducing the ‘Variant Bis’ Has Been Published

Littler on

We recently reported on the saga that followed the Constitutional Court's ruling of February 8, 2024 on the conditions for applying the partial exemption from payment of withholding tax for employers organizing shift work...more

Mayer Brown

Section 871(m) and BEAT Qualified Derivative Payment Reporting Phase-Ins Extended Two More Years

Mayer Brown on

On May 22, 2024, the US Department of Treasury and the IRS issued two important notices—one delaying the full implementation of the withholding rules on dividend equivalent payments, and the other on derivative reporting for...more

Troutman Pepper

Imminent Shift: Preparing for the T+1 Settlement Impact on Equity-Based Compensation — The Consumer Finance Podcast

Troutman Pepper on

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Sheri Adler to discuss the implications of the upcoming change in securities law that shortens the settlement period for broker-dealer transactions...more

K&L Gates LLP

Australian Federal Budget 2024-2025 - Key Tax Measures and Instant Insights

K&L Gates LLP on

The Australian Federal Government (the Government) has just released its budget for 2024-25. The K&L Gates tax team outlines the key announced tax measures and our instant insights into what they mean for you in practice....more

K&L Gates LLP

Build-to-Rent - Australian Income Tax Concessions: Foundations Laid, but Potential Cracks and Missing Features May Yet Plague a...

K&L Gates LLP on

The Australian government has, nearly 12 months after announcing them, released draft legislation to implement two key income tax incentives for build-to-rent (BTR) projects: Extending the 15% withholding tax for foreign...more

Cadwalader, Wickersham & Taft LLP

“Ephemeral” Payments and Beneficial Entitlement

Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises.  The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more

Rivkin Radler LLP

Trust Fund Recovery Penalty & The Closely Held Business

Rivkin Radler LLP on

Depending upon what you read or, perhaps more accurately, depending upon how much you believe of what you read, you may be aware that many closely held businesses are concerned about their future. Most of these survived...more

Baker Donelson

SALT Select Developments - March 2024

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

King & Spalding

ZATCA Clarifies the Requirements for Granting a 30-Year Tax Relief to Multinational Corporations under the Regional Headquarters...

King & Spalding on

The Government of the Kingdom of Saudi Arabia (“Kingdom”) in February 2021 announced its objective to limit governmental contracting with multinational companies (“MNCs”) that do not have a Regional Headquarter (“RHQ”) in the...more

International Lawyers Network

Establishing a Business Entity in the United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the...more

International Lawyers Network

Establishing a Business Entity in the Netherlands (Updated)

TYPES OF BUSINESS ENTITIES - In the Netherlands, there is a distinction between entities which qualify as legal entities (‘rechtspersonen’) and partnerships (‘personenvennootschappen’) which do not. Legal entities are...more

International Lawyers Network

Establishing a Business Entity in Sweden (Updated)

1. INTRODUCTION TO THE VARIOUS AVAILABLE LEGAL ENTITY TYPES - The most common form of legal entity to start a newco in Sweden is through a Limited Liability Company (Sw. Aktiebolag). There are, however, other types of...more

International Lawyers Network

Establishing a Business Entity in Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Kramer Levin Naftalis & Frankel LLP

Withholding Tax on Nonresidents (Article 182 A of the French Tax Code): Tax Residence Under Article 4 B of the French Tax Code...

In a recent decision, the French Administrative Supreme Court ruled on the applicability of the withholding tax provided for in Article 182 A of the French Tax Code (FTC) to the remuneration received by an employee seconded...more

International Lawyers Network

Establishing a Business Entity in Slovakia (Updated)

1. Types of Business Entities - The currently available local corporate structures for conducting business are: - General partnership - Limited partnership - Limited liability company - Joint-stock company -...more

International Lawyers Network

Establishing a Business Entity in Taiwan (Updated)

Introduction to Taiwan - In less than 50 years starting from 1949, Taiwan went from an agriculture-based economy to being an economic powerhouse and leader in the field of high-tech goods. Its Gross Domestic Product...more

International Lawyers Network

Establishing a Business Entity in Romania (Updated)

1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother company,...more

Bowditch & Dewey

Update Your 2024 Tax Withholding to Avoid Year-End Surprises

Bowditch & Dewey on

Now that the 2023 tax filing season is underway, many taxpayers are having an unpleasant surprise when they file their tax return this year and find out they are getting a much smaller refund than they were expecting, or...more

International Lawyers Network

Buying and Selling Real Estate in Ukraine (Updated)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER UKRAINIAN LAW - І. Types and specifics of real estate in Ukraine - The main types of real estate in Ukraine are the following: • plots of land; • other objects...more

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