The UK’s First-tier Tribunal (“FTT”) has denied a taxpayer a deduction for contributions to a remuneration trust on the basis that such payments did not give rise to an expense under generally accepted accounting principles...more
Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more
Section 162(m) of the Internal Revenue Code of 1986 (as amended, the “Code”) imposes a $1 million deductibility limit on compensation paid by “publicly held corporations” to “covered employees.” As reported in our previous...more
Executives of public companies looking to their personal and company compensation planning in the New Year face a host of challenges. They and their compensation committees do, however, have the benefit of long-awaited...more
The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more
On December 31, 2018, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued Notice 2019-09 (Notice) providing comprehensive interim guidance under section 4960 of the Internal...more
The Tax Cuts and Jobs Act, signed into law by President Donald J. Trump shortly before Christmas, is the most significant tax reform legislation in more than 30 years. ...more
On Friday, December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (the Act). While the emphasis of the Act focused on the reduction of corporate rates, and the repeal of the Affordable Care Act's...more
The 2017 “Tax Cuts and Jobs Act” impacts tax-exempt organizations in a variety of ways, including by reducing incentives for charitable giving, applying an excise tax on executive compensation in excess of $1 million per...more
The Tax Cuts and Jobs Act, which has been renamed the Amendment of 1986 Code, was signed into law by President Trump on December 22, 2017. Many are calling it the most sweeping overhaul to the United States tax system in...more
On Friday, December 15, 2017, Congress put forth a final version of the Tax Cuts and Jobs Act, which would signify the largest piece of tax legislation in over thirty years if signed into law. Early in the morning on December...more
On December 20, 2017, Congress passed the Tax Cuts & Jobs Act (TCJA), which now awaits President Trump’s signature. Among many changes that the TCJA will bring to current federal tax law, several will affect tax-exempt,...more
On November 20, 2017, the Senate Finance Committee released legislative text of its version of the Tax Cuts and Jobs Act, which contains proposals modifying certain executive compensation provisions of the Internal Revenue...more
Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more