Withholding Tax

News & Analysis as of

Southeast State & Local Tax: Important Developments - March 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of recent legislation around the U.S....more

FATCA – It’s Here, It’s Not Going To Be Delayed And Action May Be Needed By April 25, 2014. Is Your Fund Ready?

FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more

European CLO 2.0 Issuer Jurisdiction Quick Reference Guide

New issuance of collateralised loan obligations (“CLOs”) rose last year to its highest level since the credit crunch. 2013 saw U.S. CLO issuance rise to about US$81 billion, from US$54 billion the year before while European...more

Automatic Gratuities Are Now Wages For FICA Tax Purposes

Restaurateurs and wait staff beware: beginning this month, the IRS will classify automatic gratuities not as "tips," but as service charges reportable as regular wages which are subject to payroll tax withholdings. ...more

IRS Releases Final and New Proposed Regulations That Define “Dividend Equivalent” for U.S. Withholding Tax Purposes

On December 5, 2013, the Internal Revenue Service (“IRS”) finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid...more

Final And Proposed Regulations Address U.S. Withholding Tax On U.S. Equity Derivatives

I. Introduction - On Tuesday, December 4, the IRS and the Treasury Department issued proposed regulations that, if finalized as proposed, would dramatically increase the extent to which U.S. withholding tax is imposed...more

Southeast State & Local Tax: Important Developments - November 2013

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of recent legislation around the U.S....more

Global Financial Market Insight - November 2013

Welcome - With recovery in financial markets starting to take hold it is an exciting time to launch our Global Financial Markets Insight. The purpose of our new quarterly is to help guide new and experienced users of...more

Gaming Legal News - November 2013 • Volume 6, Number 25: Investment – Why Bulgaria?

The strategic geographical position of the country and the membership with the European Union provide a wide range of investment opportunities in Bulgaria not only for local, but for foreign investors as well. The advanced...more

IRS releases long-awaited draft FFI Agreement and previews updates to FATCA regulations

The IRS has released Notice 2013-69, including a draft FFI Agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA). ...more

Colombia issues tax havens list: 4 things to note for those doing business in Colombia

Colombia has issued its list of tax havens – an act that will negatively impact the tax effects of doing business in Colombia from or through any of these tax haven jurisdictions. The Tax Havens list was issued under...more

Serving Up Trouble: IRS Ruling on Automatic Tips

Restaurants and other employers in the hospitality industry are reminded that, as of January 2014, the Internal Revenue Service (IRS) will expect businesses to comply fully with its Revenue Ruling 2012-18. Among other things,...more

Junior Goes to College! Innovative Strategies to Save for Your Children's College Education with Pre-Tax Dollars

Overview - The cost of college tuition has gone through the roof. The average cost of a private university can range from $40,000-60,000 per year. The cost of a public university is a lot less in most cases except that...more

This Time The Employer Is Responsible For The Withholding Error

I recently blogged here about a situation involving Verizon withholding US taxes from payments to former employees who never lived or worked in the U.S....more

State & Local Tax Alert: Recent Developments in the State Taxation of Pass-Through Entities

In This Issue: - Nonresident Owner Nexus - Apportionment of Multistate Income - Entity-Level Income Tax Withholding - Composite Returns - Entity-Level Taxes - Issues Unique to S...more

U.S. District Court Decision Court Treats Physician Loans as W-2 Income Rather Than Bona Fide Debt

A recent federal court decision illustrates how “loan” arrangements between physicians and their employers, if not properly structured, may be treated as the payment of taxable compensation and the employers may be hit with...more

RMB Bond Issue in Hong Kong (a.k.a. A Delicious Dim Sum Offering!) - Part 2

A growing number of foreign and Chinese companies are accessing the renminbi (“RMB”) bond market to fund projects, enhance liquidity and improve their working capital in China. These companies can raise capital while avoiding...more

Cyprus: The Day After - The sun will still shine bright

Introduction - Cyprus has been in the spotlight recently due to the negotiations with what has become known as the troika (the International Monetary Fund, the European Central Bank and the European Commission)...more

FATCA Compliance for Investment Fund Managers Part One

U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more

Interactive Gaming And Taxes – Nevada’s Legislature Considers Gaming Amendments And The IRS Clarifies Slot Machine Withholding...

Nevada Legislature Considers Changes Critical to Gaming Industry - In the 2013 Nevada legislative session, the Nevada Legislature is considering a number of key legislative changes that would impact the gaming industry....more

2013 Amendments to United States and Japan Income Tax Treaty

On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more

"Treasury and IRS Finalize Highly Anticipated FATCA Regulations"

On January 17, 2013, the Treasury Department and the IRS issued comprehensive final regulations implementing Sections 1471 through 1474 of the Internal Revenue Code (commonly known as the Foreign Account Tax Compliance Act,...more

American Taxpayer Relief Act of 2012 Approved by Congress and Signed by the President

Summary - President Obama on January 2, 2013 signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act extends certain tax rates, tax credits, and other provisions previously enacted by other tax...more

Legal Alert: The Cliff-Hanger (Chapter One) is Over: Highlights of the American Taxpayer Relief Act of 2012

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act), effective as of January 1, 2013. In general, the Act made permanent for most taxpayers the tax rate cuts first enacted...more

Italian rules on Debt for Italian Non-Listed Companies – Italy has passed clean-up rules concerning the issuance of corporate...

The Italian Government has approved new rules concerning the issuance of corporate bonds and commercial paper through Law Decree no. 179 of October 18, 2012 on “Further Urgent Measures for Growth of the Country”, which was...more

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