News & Analysis as of

Income Taxes Beneficial Owner

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Proskauer - Tax Talks

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules – Implications for Asset Managers

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On September 13, 2024, California’s Franchise Tax Board (“FTB”) released updated proposed regulations (“Draft Regulations”), which would amend the rules regarding market-based sourcing for sales other than sales of tangible...more

Morris, Manning & Martin, LLP

FinCEN Releases Additional CTA Guidance for Disregarded Entities

In a new round of FAQ, FinCEN shed light on how entities that are disregarded from their owners for Federal income tax purposes should handle tax identification numbers (TINs) under the Corporate Transparency Act (CTA)....more

Hinshaw & Culbertson LLP

Updated FinCEN FAQs Provide Three Important Clarifications on Reporting Obligations Under the Corporate Transparency Act (CTA)

The Corporate Transparency Act (the CTA) went into effect earlier this year, although many uncertainties about the CTA's application still remain. To help remedy those uncertainties, the Financial Crimes Enforcement Network...more

Ruder Ware

The CTA’s Large Operating Company Exemption in Focus

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The Corporate Transparency Act (the “CTA”), part of the federal government’s effort to curtail money laundering by means of shell company structures, imposes disclosure requirements on most entities registered to do business...more

Allen Barron, Inc.

The Tax Consequences of Offshore Mutual Funds for US Expats and Taxpayers

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What are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open...more

International Lawyers Network

Establishing a Business Entity in the Netherlands (Updated)

TYPES OF BUSINESS ENTITIES - In the Netherlands, there is a distinction between entities which qualify as legal entities (‘rechtspersonen’) and partnerships (‘personenvennootschappen’) which do not. Legal entities are...more

Conyers

Bermuda Regulatory Outlook 2024

Conyers on

As we enter 2024 the myriad of regulatory changes can appear overwhelming. We are here to help and have set out below some key changes and issues that can impact Bermuda entities. Bermuda has introduced a corporate income tax...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Proskauer - Regulatory & Compliance

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

Lathrop GPM

The Corporate Transparency Act and Tax-Exempt Organizations

Lathrop GPM on

Beginning January 1, 2024, many types of legal entities must report information regarding their “beneficial owners” and certain other information (collectively, “BOI”) to the Financial Crimes Enforcement Network (“FinCEN”)....more

International Lawyers Network

Establishing a Business Entity in Brazil (Updated)

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they ...more

Dunlap Bennett & Ludwig PLLC

Corporate Transparency Act Requires Small Businesses To Disclose Beneficial Ownership Information Beginning In 2024

In January of 2021, Congress passed the Corporate Transparency Act of 2019 (the “CTA”) as part of the 2021 Defense Bill. Initially introduced in 2019, the CTA requires private companies to disclose their “Beneficial Owners”...more

International Lawyers Network

Establishing A Business Entity In The Netherlands (Updated)

TYPES OF BUSINESS ENTITIES - In the Netherlands, there is a distinction between entities which qualify as legal entities (‘rechtspersonen’) and partnerships (‘personenvennootschappen’) which do not. Legal entities are...more

Proskauer Rose LLP

UK Tax Round Up - March 2023 - 2

Proskauer Rose LLP on

Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

International Lawyers Network

Establishing A Business Entity In Brazil (Updated)

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they are...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update—FinCEN Issues Final Rule

On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued the highly anticipated final rule, Beneficial Ownership Information Reporting Requirements (the “Final Rule”), implementing the beneficial...more

International Lawyers Network

Establishing A Business Entity In The Netherlands (Updated)

TYPES OF BUSINESS ENTITIES - In the Netherlands, there is a distinction between entities which qualify as legal entities (‘rechtspersonen’) and partnerships (‘personenvennootschappen’) which do not. Legal entities are...more

Freeman Law

FDAP Income

Freeman Law on

The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...more

International Lawyers Network

Establishing A Business Entity In Latvia (Updated)

1. Types of Business Entities - Foreign investors may choose from the types of business entities: • Limited liability company • Joint stock company • Individual merchant • General partnership • Limited liability...more

International Lawyers Network

Establishing A Business Entity In Brazil (Updated)

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they are...more

White & Case LLP

German IP Withholding Tax

White & Case LLP on

On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more

Foodman CPAs & Advisors

Is There an Anti-Money Laundering (AML) Component to the Revision of the IRS EIN Process?

An EIN is also known as a Federal Entity Tax Identification Number (EIN) and is used to identify a business entity such as a sole proprietorship, corporation, partnership, estate, trust, and other entities for tax filing and...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

Proskauer Rose LLP on

EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more

Dechert LLP

Investment Funds Update Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Dechert LLP on

Irish Revenue Guidance on Section 110 - The Irish Revenue Commissioners (“Revenue”) issued a new Tax and Duty Manual (the “Tax Manual”) on 24 May 2018, setting out the position to deal with some of the uncertainties around...more

Ballard Spahr LLP

Investment Management Update

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IRS Issues Proposed Regulations Providing Guidance On The Tax Qualification Of Mutual Funds - On September 27, 2016, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) that provide...more

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