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Finance & Banking International Trade Tax

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New U.S. Tax Law Leaves Non-U.S. Person Estate Tax Intact

by Jones Day on

Prior to the passage of the Trump Administration's new tax bill, many had speculated on two key possible impacts for non-U.S. person private wealth bank and brokerage clients—the elimination of the estate tax exemption...more

New Tax Law (H.R. 1): Key Highlights Related to Interest Bearing Debt

by Proskauer - Tax Talks on

On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will...more

The U.S. Tax Cuts and Jobs Act: Fundamental Changes to Business Taxation

by Jones Day on

Signed into law December 22, 2017, the "Tax Cuts and Jobs Act" represents the most comprehensive reform to the U.S. federal tax code in a generation. The Act's most notable provisions include significant reductions in both...more

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

by Foodman CPAs & Advisors on

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more

UK Tax Round Up - December 2017

by Proskauer Rose LLP on

Finance (No. 2) Bill 2017-19 - The first version of the Finance (No. 2) Bill 2017-19 was published on 1 December 2017. The majority of the Bill's content had been previously announced at the Autumn 2017 Budget (see...more

Tax Reform Advisory: International Provisions

by Goulston & Storrs PC on

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to the United States tax regimes generally applicable to businesses. ...more

IRS Issues Limited Section 409A Relief to Pay Income Taxes on Pre-2009 Section 457A Deferrals

by Proskauer - Tax Talks on

The Internal Revenue Service (the “IRS”) has issued Notice 2017-75 (the “Notice”), which provides certain limited relief from the strict requirements of Section 409A of the Internal Revenue Code of 1986, as amended (the...more

U.S. Tax Reform – Key Highlights for Private Investment Funds in Tax Cuts and Jobs Act Bill

by Proskauer Rose LLP on

On Friday, December 15, 2017, the Congressional conference committee released a revised version of the Tax Cuts and Jobs Act (the "Tax Bill"). The Senate and the House are expected to vote on the Tax Bill this week. The Tax...more

How Will the New Tax Reform Bill Affect You

by Pepper Hamilton LLP on

As Congress aggressively pushes to pass the tax reform bill before the end of the year, companies and individuals are scrambling to learn how the changes will affect them. Pepper Hamilton’s Tax Practice Group has been closely...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

European authorities have opened an investigation into Inter Ikea, one of the Swiss retail giant’s two primary divisions based in the Netherlands, over “concerns that it may have been given unfair tax advantages”....more

US prosecutors seek tenfold increase in offshore evasion sentences

by Sanford Millar on

A conviction for failure to report offshore financial account now carries a far greater risk of a lengthy prison term according to Mark Daly, senior litigation counsel at the U.S. Department of Justice. US prosecutors seek...more

This Week in FCPA-Episode 80, The Last Jedi Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance- and ethics-related stories of the week, including: 1. There are several FCPA 40th anniversary pieces going up these days. The FCPA Blog is looking...more

IRS Signals Intent to Aggressively Pursue Undisclosed Offshore Accounts

by Varnum LLP on

At the recent National Institute on Criminal Tax Fraud and Tax Controversy, senior IRS and Department of Justice (Tax) officials sounded the proverbial warning alarm to taxpayers with undisclosed or offshore financial...more

EU “Black Lists” Bahrain and UAE as Non - Cooperative Jurisdiction for Tax Purposes

by King & Spalding on

On 5 December 2017, the Economic and Financial Affairs Council (ECOFIN) determined a list of 17 non-cooperative jurisdictions, which included Bahrain and the United Arab Emirates (UAE). This list was established based on...more

U.S. v. Coinbase: Virtual Currency Holders Not Outside the IRS’s Reach

by Dechert LLP on

The U.S. District Court for the Northern District of California, on November 28, 2017, ordered the international digital currency broker, Coinbase, Inc., to produce to the Internal Revenue Service (IRS) the records of...more

France Announces Its First Deferred Prosecution Agreement

In a move that could signal a new phase of government enforcement in France, on November 27, 2017, French authorities published a Convention judiciaire d’intérêt public (CJIP) with HSBC Private Bank Suisse SA (HSBC PB), the...more

DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters

At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

by Proskauer - Tax Talks on

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

by Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

Paradise Papers: The Latest Offshore Leak

by Jones Day on

Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more

Estate Planning Under the Tax Cuts and Jobs Act

If enacted, the Tax Cuts and Jobs Act could open up significant estate planning opportunities. The House bill doubles the exemptions from estate, gift and generation-skipping transfer taxes, creating new opportunities for...more

Asset Management Regulatory Roundup - November 2017 - Issue 11

by Dechert LLP on

A compact summary of the most recent regulatory and tax developments relevant to the UK asset management industry. This issue includes details on ESMA’s updated Q&As on the key information document requirements for PRIIPs;...more

How Proposed Tax Reform Will Impact Private Equity

by Foley & Lardner LLP on

Both the House of Representatives and the Senate have proposed their own versions of tax reform (the “House Proposal” and “Senate Proposal”, respectively, and together, the “Proposals”) which will drastically change the...more

What would happen to the value of cryptocurrencies if Exchanges had to Issue a Form 1099 on an annual basis?

by Sanford Millar on

The IRS issued a John DOE Summons for records of U.S. account holders of Coinbase, Inc. (“Coinbase”) a cryptocurrency exchange based in San Francisco, California. Coinbase objected to production of the records and a Summons...more

Orrick's Financial Industry Week In Review

CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief for SEFs from Certain Block Trade Requirements - On November 14, 2017, the U.S. Commodity Futures Trading Commission's Division ("CFTC") of Market...more

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