Mondaq USA: Tax > Withholding Tax
Ropes & Gray LLP
In this podcast, Brenda Coleman and Andy Howard discuss strategies for credit fund managers to address interest withholding tax issues on European investments in light of a complex and changing landscape.
Ruchelman PLLC
The U.S. Federal deficit is expected to reach $1 trillion in 2019. Meanwhile, a hedge fund billionaire recently purchased a New York City condominium ...
Ropes & Gray LLP
In an alarming development for some private equity funds, the Court of Justice of the European Union (the CJEU) has issued two judgments in the combined N Luxembourg 1 (Case C-115/16),
Littler Mendelson
On March 4, 2019, the U.S. Supreme Court held in BNSF Railway Co. v. Loos that a railroad's payment to an employee for work time lost due to an on-the-job injury is taxable compensation
Ruchelman PLLC
Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities significantly reduced regular corporate income tax
Ruchelman PLLC
On December 13, 2018, the I.R.S. issued proposed regulations under Code §§1471 through 1474 (F.A.T.C.A provisions) as well as under Code §§1441 and 1461 (withholding on non-U.S.
Ropes & Gray LLP
The term ‘private equity' is defined by the British Private Equity and Venture Capital Association as ‘any medium to long term finance provided in return for an equity stake in potentially high
Proskauer Rose LLP
On January 18, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury issued final regulations on the "pass through" deduction under section 199A[1] of the Internal Revenue Code (the "Code").
Womble Bond Dickinson
With the release January 29, 2019 of an important tax policy note (the "Note"), the OECD has introduced greater direction for its BEPS mandate to introduce proposals to address the tax challenges of the "digitalization" of the economy.
Duff and Phelps
On November 26, 2018 the U.S. Department of Treasury and the IRS released proposed regulations that provide guidance on the limitation on the business interest expense deduction for certain taxpayers.
Fenwick & West LLP
Treasury and the IRS have issued proposed regulations filling a number of gaps and providing necessary guidance on the Base Erosion and Anti-Abuse Tax (BEAT).
Ruchelman PLLC
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes ...
Davies Ward Phillips & Vineberg
The United States was initially reluctant to adopt the recommendations of the base erosion and profit shifting (BEPS) initiative spearheaded by the OECD and the G20 group of nations.
Davies Ward Phillips & Vineberg
The Tax Cuts and Jobs Act replaced the U.S. federal corporate alternative minimum tax with the base erosion and anti-abuse tax, which targets deductible payments made after 2017 by certain large corporations ...
Fenwick & West LLP
The test is not whether 80 percent received either options or RSUs.
Proskauer Rose LLP
On December 13, 2018, the Internal Revenue Service (the "IRS") and the U.S. Department of the Treasury (the "Treasury") issued proposed regulations
Cadwalader, Wickersham & Taft LLP
On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA.
Duff and Phelps
In this edition: The OECD unveiled the latest proposals to address the tax challenges of the digitalization of the economy; the IRS updated its tax statistics database with Statistic of Income data for tax year 2016;
Hunton Andrews Kurth LLP
Brexit—the formal departure of the United Kingdom (the UK) from the European Union (the EU), pursuant to the referendum held in the UK in June 2016—is imminent: the UK will cease to be a member of the EU on March 29, 2019.
Akin Gump Strauss Hauer & Feld LLP
We set out below a recap of some of the key European and international tax developments to note at the start of 2019.
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Ruchelman PLLC
The U.S. Federal deficit is expected to reach $1 trillion in 2019. Meanwhile, a hedge fund billionaire recently purchased a New York City condominium ...
Ropes & Gray LLP
In an alarming development for some private equity funds, the Court of Justice of the European Union (the CJEU) has issued two judgments in the combined N Luxembourg 1 (Case C-115/16),
Ruchelman PLLC
On December 13, 2018, the I.R.S. issued proposed regulations under Code §§1471 through 1474 (F.A.T.C.A provisions) as well as under Code §§1441 and 1461 (withholding on non-U.S.
Proskauer Rose LLP
On January 18, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury issued final regulations on the "pass through" deduction under section 199A[1] of the Internal Revenue Code (the "Code").
Ruchelman PLLC
A participating F.F.I. files Form 8966, F.A.T.C.A. Report, annually with the I.R.S. The
Skadden, Arps, Slate, Meagher & Flom (UK) LLP
The overall tenor of the proposed regulations is economic flexibility, and to that end, the proposed regulations are helpful to investors.
Shearman & Sterling LLP
On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations regarding the base erosion and anti-abuse tax (generally referred to as the "BEAT").
Ruchelman PLLC
The Treasury Department and the I.R.S. recently published proposed regulations on Code §965 (the "Proposed Regulations").
Davies Ward Phillips & Vineberg
The United States was initially reluctant to adopt the recommendations of the base erosion and profit shifting (BEPS) initiative spearheaded by the OECD and the G20 group of nations.
Ruchelman PLLC
On April 2, 2018, the I.R.S. published Notice 2018-29 (the "Notice"), describing Treasury Regulations it intends to issue with regard to the new withholding requirement on transfers of partnership interests ...
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