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Capital Gains Non-Domiciled Investors

Bradley Arant Boult Cummings LLP

VAS Holdings and the Battle Over Taxing Non-Unitary Capital Gains

Is the unitary business principle the sole test for determining whether a state can tax an apportioned share of a non-domiciliary’s capital gains under the U.S. Supreme Court’s Due Process Clause and Commerce Clause...more

Dechert LLP

Using corporate structures to own UK residential property – a dead end?

Dechert LLP on

Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more

Dechert LLP

Further Change to the UK Taxation of Carried Interest

Dechert LLP on

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

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