Avoiding Tax Consequences During Oil & Gas Restructurings
If it really didn’t matter, all this electioneering drama would be good fun, wouldn’t it? Throw in some sex and a car chase and this would work on Netflix! Regrettably, in the real world, it is less than entirely amiable....more
The inbound M&A landscape in India has been experiencing a significant surge of global interest over the past couple of years. While M&A activity globally has cooled, India has emerged as a destination of choice for companies...more
CHICAGO — U.S. Steel South Works Site Wins Massive Quantum Project -Illinois is investing in quantum computing on the Far South Side of Chicago at the former U.S. Steel South Works plant on Lake Michigan. The goal is to...more
The UAE has established comprehensive regulations to determine tax residency for individuals and businesses operating within its borders. Three key legislative instruments guide these determinations: Cabinet Decision No....more
Double taxation arises when the same income is taxed in two different jurisdictions, potentially leading to excessive tax burdens for individuals and businesses. The UAE has developed a comprehensive legal framework to...more
On July 17, 2024, the Luxembourg Minister of Finance submitted Bill of Law #8414 to the Luxembourg Parliament. The Bill proposes a series of tax measures aiming to make Luxembourg a more attractive place to work, do business...more
The newly elected UK Labour government published its call for evidence (see link here) on the taxation of carried interest on Monday 29 July 2024. This consultation by HM Treasury, cautiously anticipated following statements...more
The U.S. Supreme Court held the Mandatory Repatriation Tax (MRT) constitutional in Moore v. United States, No. 22-800, 602 U.S. _, decided June 20, 2024. The MRT requires some American shareholders of American-controlled...more
On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more
There may be a change coming to the way Canada taxes capital gains. While Prime Minister Justin Trudeau claims it will affect a minuscule percentage of Canadians, it has more than a minuscule percentage of Canadian taxpayers...more
On 9 May 2024, Skadden held the inaugural London Space Law Symposium, where six panels of Skadden representatives and industry experts discussed legal aspects of the new space economy. The event was held in the Naim Dangoor...more
In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more
On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more
In Moore v. United States, the U.S. Supreme Court rejected a constitutional challenge to the Mandatory Repatriation Tax (MRT), holding that the MRT does tax income — the realized earnings of foreign corporations — and thus is...more
The Superior Court of Connecticut (“Superior Court”) addressed in a May 7th Opinion an issue involving solar panels and related equipment. See AFL-HBAN Solar Trust c/o the Huntington National Bank v. Town of Griswold, 2024 WL...more
The British Virgin Islands (“BVI”) are home to 361,491 active companies as of 31 December 2023. This article considers the reasons for the BVI’s popularity as a jurisdiction to structure international transactions....more
Artificial intelligence is not just about chatbots. Increasingly, it is used by government for enforcement, and boards need to prepare for that, just as they need to get ready for upcoming climate disclosure requirements....more
This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
On May 10, California Governor Gavin Newsom introduced his “May Revise” of the state budget. In addition to net operating loss deduction suspensions and tax credit usage limitations, one particularly concerning corporate...more
On April 26, 2024, IRS Chief Counsel, Income Tax & Accounting (IT&A), released a legal memorandum (ILM) addressing the treatment of credit card reward liabilities for which a customer earns rewards that can be redeemed for...more
The City of Pittsburgh, in an attempt to stem the tide of collapsing real estate tax revenues from downtown Pittsburgh commercial properties, is on the verge of passing an ordinance creating a tax exemption authorized by...more
On April 22, 2024, the ‘DECREE amending the Tariff of the Law on General Import and Export Taxes’ was published in the Official Gazette of the Federation.1 This decree will be valid for two years starting from its effective...more
More Americans than ever are priced out of the housing market and President Biden has outlined steps his administration is taking to increase development of affordable housing. In the 2024 Economic Report of the...more
In an industry known for its fast-paced changes, 2024 will be no different for cannabis. For all those with an eye on the industry, the number one question remains, is this the year for rescheduling? The answer is, maybe. And...more
Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more