On 29 July, the UK government issued a call for evidence in connection with its proposed reform of the UK taxation of carried interest. Noting that the tax treatment of carried interest is the subject of considerable debate,...more
Sovereign immunity is a principle of public international law whereby one sovereign state should not seek to apply its law to another sovereign state. Alongside the jurisdictional immunity foreign sovereigns enjoy in the...more
The UK government’s “Growth Plan” (or “mini-budget”), delivered on 23 September, announced that the recent changes to the United Kingdom’s off-payroll working rules will be repealed with effect from April 2023....more
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
3/9/2021
/ Corporate Taxes ,
Financial Services Industry ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investment Management ,
IRS ,
Private Investment Funds ,
Sovereign Wealth Funds ,
Tax Assessment ,
Tax Evasion ,
Tax Liability
Businesses in the United Kingdom which engage contractors through intermediaries should prepare now for changes to the “IR35” rules that will take effect in April 2021. ...more
The UK government has made a number of announcements that may affect individuals who are UK resident taxpayers, including income tax deferral and statutory sick pay changes, during the coronavirus (COVID-19) pandemic....more
Individuals not resident in Kazakhstan are subject to taxation on certain Kazakhstan-source income. This Insight provides information on what income is taxable, what exemptions apply, and the general taxation procedure, and...more
The UK government has recently published draft legislation that, from April 2020, will require many private sector businesses engaging self-employed contractors through intermediary service companies to consider whether...more
An important update to the Controlled Foreign Corporations (CFC) regime, which is expected to be adopted in March, is being considered in Kazakhstan to narrow the scope of the CFC rules temporarily....more
HMRC provides guidance on the implications of the recent case Anson v Revenue and Customs Commissioners.
Delaware limited liability companies (LLCs) are regularly seen in many international corporate groups, including in...more
9/30/2015
/ Anson v HMRC ,
Entity Classification ,
Foreign Tax Credits ,
HMRC ,
Income Taxes ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
Partnerships ,
Tax Treaty ,
UK ,
UK Supreme Court
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
7/10/2015
/ Amortization ,
Bank Taxes ,
Banking Sector ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Dividends ,
Employment Tax ,
HMRC ,
Income Taxes ,
Loans ,
Peer-to-Peer ,
Resident Non-Domiciled (RND) ,
Tax Legislation ,
UK ,
Value-Added Tax (VAT) ,
Withholding Tax