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Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

Major Changes Proposed to UK Tax Regime for Non-resident Investors in UK Commercial Property

by Proskauer - Tax Talks on

The UK Government has announced in today’s Budget (22 November) that it is launching a consultation on extending the scope of UK tax on real estate. Currently, non-UK residents who are investors in UK land and buildings...more

House of Representatives Passes the Tax Cuts and Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison...

by Proskauer - Tax Talks on

Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late...more

Executive Regulation on Value Added Tax in the UAE

by Bracewell LLP on

The United Arab Emirates (“UAE”) Federal Tax Authority has recently published the draft Executive Regulations of Federal Decree Law No. 8 of 2017 on Value Added Tax (the “VAT Law”) which introduces a 5% VAT on the import and...more

House Passes Tax Cuts and Jobs Act: How the Senate Proposal Compares

by Shearman & Sterling LLP on

On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more

EU & Competition Law Update – November 2017

by Bryan Cave on

EU opens investigation into UK tax scheme for multinationals - The EU State aid rules are designed to stop Governments and local authorities giving companies a selective advantage, as doing so would create an unequal...more

Latest tax legislation makes for interesting reading

by DLA Piper on

The final Taxation Laws Amendment Bill 2017 (the TLAB) was introduced in the National Assembly on 25 October 2017 for ratification and signature by the President which is expected by early January 2018....more

The UK Criminal Finances Act 2017: tax evasion implications for franchisors – action steps

by DLA Piper on

The Criminal Finances Act 2017, now in force in the United Kingdom, introduces two new criminal offenses in respect of the facilitation of tax evasion. The new offenses will be committed where a corporate entity or...more

How US Tax Reform Proposals Will Affect Private Investment Funds and Asset Managers

by Latham & Watkins LLP on

Aspects of the current proposals could significantly alter the US taxation of investment funds, sponsors, and investors. Key Points: ..Major changes to US tax laws on business tax rates, interest deductibility, and...more

Do You Need a Risk Factor for Proposed U.S. Federal Income Tax Reform?

by Dorsey & Whitney LLP on

Tax reform efforts by Congress are ongoing, and the substance of the tax bills remains fluid. However, for foreign corporations with U.S. operations, there are some specific potential risks to consider, such as additional...more

Kyiv Tax Newsletter (Ukrainian) - November 2017 #2

by Dentons on

On 9 October 2017, the Government of Ukraine and the Government of the United Kingdom of Great Britain and Northern Ireland signed the Protocol for introduction of amendments into the Convention between the Government of...more

Kyiv Tax Newsletter - November 2017 #2

by Dentons on

Increased withholding tax rates in the instances of application of the Convention between the Government of Ukraine and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double...more

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

by Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

Tax Reform Proposals Would Have Significant Consequences for Foreign Multinationals Doing Business Through Affiliates in the...

by White & Case LLP on

Both the House and the Senate tax reform proposals were designed to move the United States toward a territorial tax regime and both proposals contain base erosion protections intended to prevent otherwise taxable income from...more

Tax Reform and Nonprofits: The Devil’s in the Details

by Morgan Lewis on

The Tax Cuts and Jobs Act, currently under consideration in the US House of Representatives and Senate, proposes fundamental changes to the US tax law affecting all sectors of the economy, including nonprofit organizations....more

The failure to prevent tax evasion

by WilmerHale on

The Criminal Finances Act 2017 (“the Act”)1 came into force on 30 September 2017. The Act contains a patchwork of new powers, and amendments to existing legislation, largely directed at combatting money laundering and...more

The State and Local Tax Implications of Federal Tax Reform

On November 2, 2017, Republicans in the House of Representatives released their much-anticipated tax reform bill (the House Plan). The Tax Cuts and Jobs Act (H.R. 1) proposes numerous changes to the Internal Revenue Code,...more

Proposed Changes for Estate, Gift and Generation-Skipping Taxes Introduced in Tax Cuts and Jobs Act - Update

by McDermott Will & Emery on

In Depth - UPDATE: On November 9, 2017, the Senate Finance Committee released “policy highlights” of its forthcoming version of the Tax Cuts & Jobs Act. Like the House bill, the Senate version doubles the “death tax”...more

Possible Favorable Impacts on Inbound U.S. Real Property Investments under the Proposed Tax Act

by Charles (Chuck) Rubin on

The proposed Act has provisions that will provide benefits to non-U.S. persons making investments into U.S. real property. For foreign persons investing individually (or through pass-through entities) in U.S. partnership...more

Senate Tax Proposal Includes Comprehensive Business Tax Reform Measures

by McDermott Will & Emery on

The Senate Finance Committee Chairman’s Mark of the Tax Cuts and Jobs Act includes substantial proposed changes to the corporate and international business taxation rules. While this proposal will evolve further in committee...more

Avoiding the “Automatic” $10,000 Penalty for Late Filing of International Information Returns

by Sanford Millar on

Taxpayers who fail to timely file international information returns, such as Form 3520, Annual Return of a Controlled Foreign Corporation are subject to an automatic assessment of $10,000 per return per year up to a maximum...more

Senate Finance Committee releases tax reform bill

by Dentons on

On November 9, Orrin Hatch, Chairman of the US Senate Finance Committee, unveiled the Senate's version of comprehensive tax reform. Chairman Hatch released the Senate proposal following approval of the US House of...more

Tax Reform Bill May Eliminate Need to Limit Credit Support Attributable to CFCs for US Corporate Borrowers

by White & Case LLP on

Under current law, the direct or indirect pledge of the assets of a "controlled foreign corporation" (a "CFC") as collateral security for, among other things, a borrowing of a US person is treated as an investment in US...more

House Tax Bill Would Fundamentally Change Executive Compensation and Employee Benefit Practices

by Morrison & Foerster LLP on

On November 2, 2017, the House Ways and Means Committee unveiled the Tax Cuts and Jobs Act (the “Bill”), which, if enacted, could dramatically impact certain aspects of executive compensation and employee benefit issues. The...more

House Releases "Tax Cuts and Jobs Act of 2017" (HR 1)

by King & Spalding on

On November 2, House Ways and Means Committee Chairman Kevin Brady (R-TX) released the “Tax Cuts and Jobs Act of 2017” (HR 1, or the “Bill”). On November 3, the Chairman’s Mark of the Bill was released, and Chairman Brady...more

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