News & Analysis as of

Capital Gains Tax Avoidance

Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

Rivkin Radler LLP on

An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

Rivkin Radler LLP

Tax Authorities of the World Unite? Not Quite, But the IRS Joins the Movement to Tax the Rich

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Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more

Davies Ward Phillips & Vineberg LLP

Government of Canada Releases Package of Proposed Domestic and International Tax Legislation

The Department of Finance (Finance) released draft tax legislation for public consultation on August 4, 2023, with a stated focus on promoting tax fairness and a clean economy. The most significant item released is the...more

Rivkin Radler LLP

Related Party Transactions Converting Gain Into Ordinary Income – Be Careful Out There

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To avoid the manipulation of tax consequences to which transactions between certain related taxpayers may be susceptible, the IRS and the Courts generally require that such transactions be closely scrutinized to ensure that...more

Rivkin Radler LLP

Thinking About ‘Avoiding’ NY Tax Increases? Then Think About The False Claims Act

Rivkin Radler LLP on

According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more

Proskauer Rose LLP

UK Tax Round Up - January 2021

Proskauer Rose LLP on

UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more

Vinson & Elkins LLP

UK Budget 2020: Tax Perspectives

Vinson & Elkins LLP on

Today, UK’s Chancellor announced the first post-Brexit Budget, a fiscal stimulus package of £30 billion. As expected from the Conservative Party’s 2019 election manifesto, there are no changes to the headline rates of...more

McDermott Will & Emery

Changes to Non-Domiciled Status Announced in The UK Summer Budget 2015

McDermott Will & Emery on

Following the United Kingdom’s General Election in May, George Osborne, Chancellor of the Exchequer, gave the new government’s first budget speech on 8 July 2015. In his speech, Mr Osborne announced some changes to the tax...more

Morgan Lewis

IRS Issues Notices Regarding Certain Structured Transactions

Morgan Lewis on

Parties that enter into “basket option contracts” and “basket contracts” should be aware that the IRS is likely to challenge such transactions and that they have a new obligation to report the transactions to the IRS or face...more

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