News & Analysis as of

Withholding Tax Investors

DLA Piper

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

DLA Piper on

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

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

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 Italy (Updated)

1. Types of Business Entities - Italian law provides multiple forms of organizational structures to do business in Italy. They differ from one another due to the extent of liability undertaken by its members. In...more

Goodwin

Public Consultation on a Common EU-Wide System for Withholding Tax Claims on Dividend and Interest Payment

Goodwin on

The EU Commission published a public consultation based on its initiative to introduce a common EU-wide system for withholding tax on dividend or interest payments, which includes a system for tax authorities to exchange...more

A&O Shearman

20 Questions for Qualifying Asset Holding Companies (QAHCs)

A&O Shearman on

The Finance Act 2022 (FA22) has introduced a new regime for qualifying asset holding companies (“QAHCs”). The new regime, which came into force on 1 April 2022, offers qualifying companies a wide range of tax benefits,...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 world’s...more

International Lawyers Network

Establishing A Business Entity In Italy (Updated)

1. Types of Business Entities - 1.1 Premises - The Italian law provides multiple forms of organizational structures in order to do business in Italy, which differ from one another due to the extent of the liability...more

International Lawyers Network

Establishing A Business Entity In The United States

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 world’s...more

McDermott Will & Emery

Weekly IRS Roundup January 18 – January 22, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 18, 2021 – January 22, 2021... On January 20, President Biden’s chief of staff, Ronald...more

Dorsey & Whitney LLP

“ECI” and its Trap for Unwary Canadian Investors in Partnerships and LLCs

Dorsey & Whitney LLP on

A Canadian which holds a partnership interest in a U.S. or non-U.S. partnership that has “effectively connected income” (“ECI”) is subject to U.S. tax withholding with respect to the Canadian partner’s allocable share of the...more

Farrell Fritz, P.C.

Continuing Economic Distress: Withholding Taxes And The Risk Of “Self-Help”

Farrell Fritz, P.C. on

Stimulus Legislation Limbo- In has been 192 days since the President declared a national emergency concerning the COVID-19 outbreak. Across the country, businesses and communities were immediately placed on lockdown[ii] in...more

Fenwick & West LLP

Structuring Secondary Sales to Maximize Capital Gains – A Primer for Private Companies

Fenwick & West LLP on

As private companies seek to stay private longer, many try to offer interim liquidity opportunities to their employees. These opportunities include secondary sales, where employees sell their common shares to investors, often...more

Akin Gump Strauss Hauer & Feld LLP

Upper Tribunal Overturns Decision on Tax Treatment of Management Fee Rebates

The Upper Tribunal (UT) has found that amounts paid by Hargreaves Lansdown (HL) (an investment platform service provider) to its customers, which represented rebates received from investment fund managers, were “annual...more

Dechert LLP

International Capital Markets Newsletter Issue 1 – Spring 2019: International Securities Market – Two Years On

Dechert LLP on

In March 2017, the London Stock Exchange Group (“LSEG”) announced a new debt multilateral trading facility (“MTF”) targeted at institutional and professional investors, the International Securities Market (the “ISM”). The ISM...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

McDermott Will & Emery

New Regulations on Withholding Income Tax for Overseas Investors in China

McDermott Will & Emery on

To promote the growth of foreign investment, the “Notice on Policies concerning Temporarily Not Levying Withholding Tax on Distributed Profit used for Direct Investment by Overseas Investors” was jointly issued on December...more

Troutman Pepper

U.S.-India Newsletter - Vol. 2016, Issue 3

Troutman Pepper on

Summer 2016 was a season of change. In Europe, we saw the "Brexit," with the United Kingdom voting to withdraw from the European Union. The June referendum sent shockwaves through the business and finance communities and...more

Troutman Pepper

Recent Changes to the India-Mauritius Tax Treaty: What Does This Mean for American Investors?

Troutman Pepper on

The amendments may cause some uncertainty and anxiety for U.S. investors as they consider how these changes will impact business, income, profitability and the benefits or drawbacks of investing in India through Mauritius....more

Dechert LLP

German Investment Taxation – Reform Ahead

Dechert LLP on

The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015. The Draft Bill contains significant changes to the German tax...more

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