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Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more

PATH Act Creates New FIRPTA Withholding Tax Rate and Exemption for Foreign Pension Funds

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed into law on December 18, 2015, has resulted in a number of changes to the taxation of investments in U.S. real property by foreign investors. Among...more

The New Landscape for Inversions: IRS and Treasury Change the Rules

The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more

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