Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
Podcast - La Prima por Fusión
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
10 Things Lawyers Should Know About BVI Transactions
Tax Planning Under a Biden Presidency
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Tax Provisions in Business Acquisition Agreements
It was a relatively light Budget for the real estate sector. Highlights included the long-awaited announcement of the rate of the residential property developer tax and some reform of business rates....more
The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more
The Opportunity Zone program created by the Tax Cuts and Jobs Act of 2017 (the “TCJA”) allows taxpayers that realize certain gains to elect to defer the federal income tax on such gains by reinvesting them into Qualified...more
After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more
EXECUTIVE SUMMARY - 1. Cybersecurity threats. Cybersecurity preparedness is essential in 2018 as the risk of, and associated adverse impact of, breaches continue to rise. The past year redefined the upward bounds of the...more
• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more
For the second time in just over a year, the U.S. Court of Appeals for the Sixth Circuit reversed the United States Tax Court and affirmed the right of a taxpayer to structure its affairs in a manner that takes into account...more
A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more
On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more
Tax: HMRC Publishes Filing Dates for New AIFM Mechanism for Partnership Deferred Remuneration Arrangements - The Finance Act 2014 introduced a provision intended to help partnerships (including LLPs) that are AIFM...more
In CCA 201501013, the IRS found that an offshore fund making loans to U.S. borrowers was engaged in a U.S. trade or business where multiple loans owned by the fund were originated by an agent of the fund. This conclusion is...more