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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 17, 2023 – July 21, 2023....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 12, 2023 – June 16, 2023...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2023 – April 21, 2023...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 18, 2021 – January 22, 2021... On January 20, President Biden’s chief of staff, Ronald...more
With the implementation of the Tax Cuts and Jobs Act of 2017, it was only a matter of time before the IRS issued a new W-4 Employee Withholding Certificate form. Employers use the W-4 to determine how much pay to withhold...more
On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more
European Leveraged Finance Alert Series: Issue 1, 2019 - New Polish laws, effective 1 January 2019, have reformed the tax treatment of a number of different taxable business activities. In particular, the Ministry of...more
• Under Swiss law, Swiss employers must levy an employment withholding tax on the salary received by foreign nationals who do not hold a permanent residence permit. • Only taxpayers whose salary exceeds a certain amount...more
On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-29 (the “Notice”), announcing the intention of the IRS and the Department of the Treasury to issue regulations regarding the withholding requirements...more
As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests. ...more
Congress and the Administration have been busy recently, enacting not only the "Tax Cuts and Jobs Act" or "TCJA" on December 22, 2017, but also a Continuing Resolution on January 23, 2018, and the Bipartisan Budget Act of...more
More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more
Since January 1, 2018, the date changes to the tax law passed by Congress at the end of December (the “Tax Act”) became effective and provided new individual marginal tax rates and modified deductions, the Internal Revenue...more
On January 11, 2018, the IRS issued its new withholding tables to assist employers with processing payrolls and withholding federal income tax under the new Tax Reform Act signed into law late last year (the “Act”). IRS...more
New tax provisions have significant impact on structuring mergers and acquisitions. In light of the recent passage of HR 1 (the Act) and ensuing sweeping changes to tax law in the United States, certain tax-related aspects...more
President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more
New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions. On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more
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
After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more
On 10 March 2016, the Senate Economics Legislation Committee published the Report on the proposed legislation which will introduce a new system for taxing attribution managed investment trusts (AMITs). Committee's Views on...more
In This Issue: - Two Combined Reporting Decisions Highlight Issues Involving “Permissive” Combined Reporting - New York State Corporate Tax Reform Legislation Enacted – What You Need to Know - Appellate Court...more