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Tax Reform Tax Avoidance

Gray Reed

IRS Further Combats Basket Contract Transactions with Proposed Regs

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The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them...more

Woods Rogers

IRS Announces New Initiatives to Restore Fairness to Tax System

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On September 8, 2023, the IRS announced the start of a “sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promotors...more

Rivkin Radler LLP

Trump’s Returns and Congress – Lessons, Next Steps?

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Last Friday, December 30, 2022, during the final hours of the 117th Session of Congress, the House Ways and Means Committee – through which all tax legislation passes – released redacted versions of six years of Mr. Trump’s...more

A&O Shearman

Volatile Reaction to UK “Mini-Budget”

A&O Shearman on

Bank of England market intervention after presentation of tax package - On 23 September, the new U.K. Government conducted the emergency fiscal event it had scheduled when taking power at the beginning of the month. Many...more

Proskauer Rose LLP

UK Tax Round Up - December 2021

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UK Case Law Developments - Taxpayer treated as receiving distribution in tax avoidance case - We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more

Bennett Jones LLP

Income Tax Update from the Supreme Court of Canada: The GAAR Does Not Apply to Treaty Shopping

Bennett Jones LLP on

The Duke of Westminster Principle Still Lives On for Tax Planning - On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC...more

Cadwalader, Wickersham & Taft LLP

The UK’s Autumn Budget 2021 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (UK) Autumn Budget for 2021 on 27 October 2021. The Budget was delivered against the backdrop of the UK’s ongoing recovery from the Covid-19 pandemic and the...more

Cadwalader, Wickersham & Taft LLP

UK Autumn Budget 2021 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Autumn Budget for 2021 on 27 October 2021. The Budget was delivered against the backdrop of the UK’s ongoing recovery from the Covid‑19 pandemic and the...more

Proskauer Rose LLP

UK Tax Round Up - July 2021

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In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more

Proskauer Rose LLP

UK Tax Round Up - January 2021

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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

Proskauer Rose LLP

UK Tax Round Up - November 2020

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UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more

Hogan Lovells

Tech Tax – Looking Forward to 2020

Hogan Lovells on

Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more

Alston & Bird

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

Alston & Bird on

On April 2, in quick succession, the IRS and Treasury announced notices addressing two provisions added by the Tax Cuts and Jobs Act (TCJA): the repatriation tax under Section 965 and withholding on non-publicly traded...more

Proskauer Rose LLP

UK Tax Round Up - September 2017

Proskauer Rose LLP on

UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

K&L Gates LLP

Italian Tax Reform

K&L Gates LLP on

The Italian Government has recently approved a new decree, which reshapes the definition of abuse of law and tax avoidance and changes the rules on the statute of limitations in the event of tax crimes. The decree also...more

Morgan Lewis

Tax Measures in the 2014 UK Autumn Statement

Morgan Lewis on

Announcements support UK growth and prevent tax avoidance. On 3 December, UK Chancellor of the Exchequer George Osborne made a number of tax-related announcements in the 2014 Autumn Statement. Given the government’s...more

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