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Capital Gains Exemptions

Barnea Jaffa Lande & Co.

NPOs Receive Exemptions from Real Estate Betterment Levies

The Israeli Supreme Court handed down a precedent-setting ruling recently in the Evangelical Episcopal Church case. According to the ruling, Israeli NPOs may receive an exemption from paying real estate betterment levies to...more

Bennett Jones LLP

Supreme Court of Canada Upholds Treaty-Based Canadian Holding Structure

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On November 26, 2021, the Supreme Court of Canada (the SCC) released its highly anticipated decision in Canada v Alta Energy Luxembourg SARL, 2021 SCC 49 [Alta Energy Lux], that addressed treaty-based holding structures and...more

Davies Ward Phillips & Vineberg LLP

Top Court Blesses Treaty-Shopping Arrangement: The Alta Energy Decision

The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy). Six of the nine justices held that the Canadian statutory general...more

Davis Wright Tremaine LLP

Washington Enacts New Capital Gains Tax for 2022 and Beyond

Washington's legislature passed a new capital gains tax in April (Engrossed Substitute S.B. 5096), which was signed by Governor Inslee on May 4, 2021. The new law will take effect January 1, 2022....more

McDermott Will & Emery

Lifetime Gifting in the United Kingdom: Opportunities and Clarifications

McDermott Will & Emery on

The Office of Tax Simplification (OTS) recently released a report on simplifying the design of UK inheritance tax (IHT). This article highlights areas where taxpayers might take advantage of existing opportunities to make...more

Mintz

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

Mintz on

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

Foley & Lardner LLP

U.S. Tax Court Ruling Exempts Gain on Foreign Partner's Sale of a Partnership Interest

Foley & Lardner LLP on

On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more

Latham & Watkins LLP

US Tax Court Exempts Gain on Sale of a Partnership Interest

Latham & Watkins LLP on

Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more

Dechert LLP

German Investment Taxation – Reform Ahead

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

Ballard Spahr LLP

How the New ‘Fiscal Cliff’ Law Affects the Municipal Bond Market

Ballard Spahr LLP on

The American Taxpayer Relief Act of 2012 (the Act), passed by the Senate and the House and Representatives on New Year’s Day and signed by the President on January 2, 2013, includes several direct and indirect consequences...more

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