Imminent Shift: Preparing for the T+1 Settlement Impact on Equity-Based Compensation — The Consumer Finance Podcast
Navigating the Once-Obscure German Nonresident Withholding Tax
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Cum-Ex Dividend Trade Investigations
According to statistics released by the Administrative Office of the U.S. Courts for the twelve-month period ending Dec. 31, 2025, bankruptcy filings by businesses rose 7.1 percent and non-business filings increased by 11.2...more
In general, foreign funds are not freely movable into China. There is a long history of exercising comprehensive control over foreign investment since China opened its door in the early 1980s. As the economy continues to...more
On May 12, 2026, a Bill entitled the “Fair Trusts for Fiscal Responsibility Act” was introduced in the Senate by Sen. Patty Murray and co-led by Sen. Ron Wyden. The proposed legislation would impose an annual “withholding...more
In addition to the several new tax measures announced in the Australian Federal Budget handed down on 12 May 2026, the Treasurer reiterated his commitment to the previously announced significant non-resident Capital Gains Tax...more
El Consejo de Estado de Colombia, mediante auto del 7 de mayo de 2026, suspendió en forma provisional los efectos de los artículos 2 al 8 del Decreto 572 de 2025, normas que habían introducido modificaciones sustanciales a...more
L’administration fiscale a publié ses commentaires détaillés sur les modalités d’application du dispositif prévu à l’article 119 bis A, II du CGI, dans sa version issue de l’article 96 de la loi n° 2025-127 du 14 février 2025...more
The Court of Appeal has confirmed in Burlington Loan Management DAC v HMRC that “obtaining the benefit of” a tax treaty is not the same as “taking advantage of” it. The treaty anti-abuse rule will only apply where the...more
On April 24, U.S. Customs and Border Protection extended a limited waiver of the Jones Act that had originally been granted on March 19. As a result of the waiver, non-U.S. flagged vessels are permitted to transport certain...more
On April 24, President Trump extended the existing waiver of the Jones Act (the “Waiver”), which permits foreign-flagged vessels to transport oil, fuel and fertilized between U.S. ports. The original waiver was set to expire...more
In welcome news for secondary debt markets, the UK Court of Appeal upheld decisions in the lower tribunals in favour of the taxpayer that the “principal purpose test” (PPT) in the UK/Irish double tax treaty (DTT) did not...more
The much-anticipated Court of Appeal judgment in HMRC v. Burlington Loan Management DAC [2026] provides some welcome clarity and reassurance to taxpayers (and their advisers) grappling with the application of purpose tests in...more
1. Types of business entities - The most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”), the corporation (“Sociedad Anónima” or “SA”)...more
There are significant tax developments underway that have the potential to materially impact private equity debt and investment structures in Australia. Private equity investors can expect the Australian Taxation Office (ATO)...more
There are significant tax developments underway that have the potential to materially impact transaction financing and investment structures in Australia. ...more
La Cour administrative d’appel de Paris confirme l’application d’une retenue à la source de 10 % à une somme versée au titre d’un « accord de licence » par une société française à une société sud-coréenne, qualifiant cette...more
Saisi d'un recours pour excès de pouvoir, le Conseil d'État juge que le délai spécial de réclamation applicable aux retenues à la source (31 décembre de l'année suivant celle au cours de laquelle la retenue a été opérée)...more
The Massachusetts Department of Revenue (“DOR”) has implemented a withholding tax on non-resident sellers of real estate when the real property sells for at least $1 million as codified in 830 CMR 62B.2.4....more
On February 23, the Brazilian Federal Government published Decree No. 12,851/2026, delegating regulation of the method for proving the allocation of financing to exports to the Special Department of Federal Revenue of Brazil...more
Following a prolonged period of uncertainty on application of the India-Ireland double taxation treaty (IIDTT) to aircraft leasing arrangement between Irish special purposes entities, particularly those availing of the Irish...more
This fourth instalment of our five-part series examines some of the key tax considerations that arise in structuring and negotiating European back-leverage transactions....more
In recent years, we have seen tax authorities increasingly relying on anti-abuse arguments to deny relief under double tax treaties. In this briefing, we consider three themes that have been coming up frequently in practice...more
A new federal law enacted last year provides a tax benefit to employees who receive overtime pay – but calling it a “No Tax on Overtime” law is a bit of misnomer. For starters, OT pay remains taxable and subject to...more
1. WHAT HAPPENED? HM Revenue & Customs (HMRC) has paused operation of its long‑standing practice under which, where UK‑source yearly interest was paid gross to a treaty-entitled overseas lender before HMRC clearance was...more
On January 15, 2026, the IRS and Treasury issued Notice 2026-13, which updated the guidance available to plan administrators tasked with providing rollover notices and safe harbor special tax notices designed to comply with...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 12, 2025 – January 12, 2026....more