News & Analysis as of

Income Taxes Financial Services Industry

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 -
Mayer Brown

Exploring the Unexpected and Often Unwelcome Federal Income Tax Consequences of Debt Modifications

Mayer Brown on

As a number of debt instruments issued several years ago in a relatively low interest rate environment now have their maturity date approaching in a much higher interest rate environment, borrowers are increasingly seeking to...more

International Lawyers Network

Establishing a Business Entity in New Zealand (Updated)

TYPES OF BUSINESS ENTITIES - There are various entities available in New Zealand from which a business can be operated. The most commonly adopted entities are: 1. Company (including Incorporated Joint Venture (JVC))...more

Cadwalader, Wickersham & Taft LLP

Treasury Cries “Uncle” to Crypto Industry: Crypto Reporting Delayed

On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year.  Persons engaged in...more

Gray Reed

Release the Kraken Tax Transaction Information

Gray Reed on

On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information.  Specifically, Kraken was ordered to produce the...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Makes Permanent Its Fast-Track Corporate Private Letter Rulings

On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more

Cadwalader, Wickersham & Taft LLP

Playing the Waiting Game on Crypto Tax Reporting

As previously discussed here, the IRS published guidance in December 2022 effectively postponing the January 1, 2023 effective date for certain digital asset broker reporting rules until final regulations are promulgated. To...more

BakerHostetler

New Crypto Payment and Web3 Products Launch; UK Seeks Input on DeFi Taxation; OFAC Fines Crypto Exchange; SEC, DOJ, CFTC Continue...

BakerHostetler on

Multiple Financial Services Firms Announce New Crypto Products - A major U.S. financial services firm recently launched its Crypto Credential product, “a set of common standards and infrastructure that will help verify...more

Davies Ward Phillips & Vineberg LLP

Canada Releases Revised Draft Legislation on New Interest Deductibility Rules

The Department of Finance (Canada) (Finance) has released revised draft legislation on the proposed rules regarding excessive interest and financing expenses limitation (EIFEL). The revised draft legislation, released on...more

Proskauer - Tax Talks

BlueCrest FTT Decision –  Salaried Member Rules and Asset Managers

Proskauer - Tax Talks on

The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more

Davies Ward Phillips & Vineberg LLP

Canada Confirms Intention to Institute New Interest and Deductibility Rules

The Department of Finance (Canada) (Finance) released draft legislation on February 4, 2022 that would limit the deduction of “interest and financing expenses” to a fixed percentage of earnings before interest, taxes,...more

Dechert LLP

Luxembourg investment funds – Tax reporting obligations to be complied with by 31 May 2022

Dechert LLP on

Since 1 January 2021, certain corporate Luxembourg investment funds (i.e. Part II UCI, SIF and RAIF, as defined below) that hold real estate assets located in Luxembourg are subject to a special taxation, the so-called real...more

Hogan Lovells

With a New Year, Brings a New Rate . . . The Transition from LIBOR Is Now Here

Hogan Lovells on

In March 2021, the Financial Conduct Authority (FCA) and the ICE Benchmark Administration, the administrator of LIBOR, announced that sterling, euro, Swiss franc and Japanese yen LIBOR panels, as well as panels for one-week...more

International Lawyers Network

Establishing A Business Entity In New Zealand (Updated)

TYPES OF BUSINESS ENTITIES - There are various entities available in New Zealand from which a business can be operated. The most commonly adopted entities are: 1. Company (including Incorporated Joint Venture (JVC)) ...more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Kohrman Jackson & Krantz LLP

New Tax Rule Changes Reporting Requirements For Venmo, Paypal, Cash App

A new tax rule will see the Internal Revenue Service (IRS) gain information on income small businesses receive via transactions on popular payment applications. As of Jan. 1, 2022, businesses that accept more than $600 per...more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Hogan Lovells

Coronavirus: The Hill and the Headlines, March 2021 # 12

Hogan Lovells on

In Washington: President Biden on Tuesday began what is expected to be a weeks-long sales pitch to tout the new coronavirus relief package. Biden visited Smith Flooring in Chester, Pennsylvania, a small business that received...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

Morgan Lewis on

Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

K&L Gates LLP

Trump v. Biden: What Might the Next Four Years Look Like?

K&L Gates LLP on

Quickly approaching November 3, 2020, we are in the final days of what is expected to be a contentious and consequential presidential election in the United States. With the whirlwind news cycles at the end of the campaign...more

Akin Gump Strauss Hauer & Feld LLP

What's New in Washington - July 2020

The legislative calendar continues to march forward as members of Congress adapt to their new work environments and routines. With the House and Senate both in session this week, Senate Republicans plan to roll out their...more

Morgan Lewis

Congress Repeals Nonprofit Parking Tax and Modifies Private Foundation Tax on Net Investment Income

Morgan Lewis on

The Taxpayer Certainty and Disaster Tax Relief Act of 2019 (the Act) was signed into law on December 20, 2019, as part of the Further Consolidated Appropriations Act, 2020 (PL 116-94). The Act contained a number of changes...more

Latham & Watkins LLP

Blockchain & Cryptocurrency Regulation 2020: United Kingdom

Latham & Watkins LLP on

Although still actively developing, current UK policy thinking in relation to cryptocurrencies was set out by the UK Cryptoassets Taskforce in its Final Report (the “Taskforce Report”), published in October 2018. The...more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Dechert LLP

Financial Services Quarterly Report - Third Quarter 2019: Developments in the UK Tax Treatment of Fee Rebates and Trail...

Dechert LLP on

UK investment managers paying fee rebates, loyalty bonuses or similar payments to UK investors and certain non-UK investors in collective investment schemes should note recent case law developments regarding the tax treatment...more

Morrison & Foerster LLP

New York Revises Draft Apportionment Regulation on Specified Services That Will Affect Many Businesses, Including the Financial...

The New York State Department of Taxation and Finance has made several significant revisions to its draft corporate income tax regulation for the sourcing of receipts from other services and other business activities. Draft...more

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