News & Analysis as of

Capital Gains Dividends

A Comparison of the House and Senate Tax Bills

by Holland & Knight LLP on

It has been a busy week in Washington, D.C., as Congress works its way through tax reform. The House Ways and Means Committee completed its "markup" of the House bill this week, paving the way for a floor vote on the measure...more

Dutch dividend withholding tax

by Hogan Lovells on

On an international front, it has been announced that the new cabinet to be established in the Netherlands intends to abolish Dutch dividend withholding tax with effect from 1 January 2019. ...more

Carried Interest tax regime in Italy (art. 60 of Law 96/2017)

The new tax regime aims at discounting the taxation of the excess profit (i.e. profit in excess of the amount that the managers have contributed to the undertaking) attributed to investment managers or managers of target...more

Italy passes new rules for carried interest

by Hogan Lovells on

The Italian Government has at last put an end to the controversy around the characterisation of 'carried interest' for tax treatment purposes. By Law Decree no. 50 of 24 April 2017, which is to be brought into law by 23 June...more

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

by Bilzin Sumberg on

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

German Cum/Ex-Trades: Enhanced Risks and Industry-Wide Challenges

by WilmerHale on

The German and international financial industries and their advisors have come under new pressure to investigate so-called 'cum/ex' trades conducted between 2000 and 2012. For many years, tax authorities and criminal...more

Obama's Budget Proposals Expand Application of Net Investment Income Tax and Address Carried Interest

by Proskauer Rose LLP on

On February 9th, President Obama released his Budget Proposals for 2017 (the "Budget Proposals"). The Budget Proposals include the following proposals that may affect private investment fund managers...more

European M+A News, Winter 2016

by Morrison & Foerster LLP on

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

The Built-In Gains Tax - S Corporations Are Gaining Ground

Many business owners are aware that, if a business is operated through a C corporation, the corporation pays tax on the profits and, when the profits are distributed to the shareholders in the form of dividends, the...more

MoFo Tax Talk - Volume 8, No. 3

by Morrison & Foerster LLP on

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

German Investment Taxation – Reform Ahead

by Dechert LLP on

The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015. The Draft Bill contains significant changes to the German tax...more

Tax Proposals to Eliminate Interest Deductions Miss the Mark

by Pepper Hamilton LLP on

The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies. In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more

Guide To Doing Business in New Zealand: Taxation (Updated)

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

Planning For Qualified Dividend Income When Taking Foreign Companies Public - Tax Update Volume 2015, Issue 2

by Pepper Hamilton LLP on

Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income...more

Tax Reform and the Timber Industry

by K&L Gates LLP on

This alert provides an overview of various timber tax issues in play as part of the tax reform debate. The alert is drawn from several sources, including former House Ways and Means Committee Chairman David Camp’s tax reform...more

MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

by Morrison & Foerster LLP on

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

Sale of dividend claims to third parties by non-resident taxpayers

by Latham & Watkins LLP on

Federal Ministry of Finance: If the capital gain is not taxable in Germany, the correspondent dividends are taxed. With its circular letter dated 26 July 2013, the Federal Ministry of Finance comments on the tax...more

Tax Newsletter - Second Edition 2013: A Review Of PRC And Hong Kong Tax Developments

by DLA Piper on

In This Issue: *CHINA: - HEADQUARTER AND BRANCHES VAT FILING UNDER THE VAT PILOT PROGRAM - FURTHER CLARIFICATION ON BENEFICIAL OWNERSHIP OF DIVIDENDS UNDER DTA WITH HONG KONG - PE ON SECONDMENT...more

No 15% Qualified Dividend Rate For CFC Inclusion

by Charles (Chuck) Rubin on

Back in 2011, we reviewed a Tax Court case that determined that income inclusion under the controlled foreign corporation (CFC) rules, while taxed like a dividend at ordinary income rates, could not qualify for the lower 15%...more

The Gwartz Decision: The GAAR Is Not A Filler

by Dentons on

In Brianne Gwartz v. The Queen, 2013 TCC 86, the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had been realized by a family trust and allocated to the minor-aged taxpayers in...more

Expatriation Lite: Leaving The U.S. Tax System While Retaining Your Citizenship

by Bilzin Sumberg on

As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more

Readjustment of Taxation of Free Floating Dividends and of Fiscal Unity – Current Legislative Procedures

by K&L Gates LLP on

Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more

Congress Approves The American Taxpayer Relief Act Of 2012, Preventing "Fiscal Cliff"

by Polsinelli on

After much contention,Congress passed the American Taxpayer Relief Act of 2012, and President Obama signed the legislation on January 2, 2013. The Act avoids automatic sunset provisions that were scheduled to take effect...more

Estate Planning & Federal Tax Update - Winter 2013

With the American Taxpayer Relief Act of 2012 (the “ATRA ”) passed and the fiscal cliff safely averted, the time has come to turn your attention to your estate plan. What Did the ATRA Accomplish? The fiscal cliff...more

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