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UK Tax Round Up - March 2019
At the end of February, the Court of Justice of the European Union (CJEU) issued two judgments addressing the circumstances ...
European Union
11 Apr 2019
2
Proposed Anti-Hybrid Regulations Under Sections 267A, 245A, And 1503(d)
On December 20, 2018, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") ...
United States
30 Jan 2019
3
UK Tax Round Up - December 2018
On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK) Ltd) ...
UK
7 Jan 2019
4
UK Tax Round Up: October 2018
The Autumn Budget will be presented later today and the Finance Bill 2019 will be published on 7 November.
UK
1 Nov 2018
5
General UK Tax Developments: October 2018
The Chartered Institute of Taxation (CIOT) has published its response to the profit fragmentation rules published on 6 July 2018 in Clause 10 and Schedule 6 of the draft Finance Bill 2019.
UK
1 Nov 2018
6
UK Tax Round Up: May 2018
We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this has been resolved rapidly ...
UK
7 Jun 2018
7
The Tax Cuts And Jobs Act
Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the "Tax Cuts and Jobs Act".
United States
3 Nov 2017
8
UK Tax Round Up: October 2017
Welcome to the October 2017 edition of the Proskauer UK Tax Round Up. The past month has been a number of interesting case decisions among other developments.
UK
30 Oct 2017
9
Zero Dividend Shares Are Ordinary Share Capital
This decision concluded that such shares are OSC.
UK
12 Sep 2017
10
BEPS Update: OECD Multilateral Instrument Signed
On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion...
United States
13 Jun 2017
11
Wealth Management Update (May 2017)
The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.4%, down 0.2% from April.
United States
9 May 2017
12
BEPS: Update On Action 6 On Treaty Benefits
In our previous post published on 6 December 2016 we described the OECD's BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion...
United States
3 Feb 2017
13
BEPS: OECD Releases Multilateral Tax Treaty Convention
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting was released by the Organisation for Economic Co-operation and Development...
United States
9 Dec 2016
14
Key Takeaways From IBA Annual Conference Panel
Materials from the presentation are available to IBA members on their website.
Worldwide
17 Oct 2016
15
UK Supreme Court Case Of Anson v. HMRC [2015] UKSC 44
The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC as transparent for UK tax purposes.
UK
13 Jul 2015
16
New Developments On International Automatic Financial Information Exchange And Disclosure
We last updated our readers in February 2014 on issues related to the disclosure and automatic exchange of financial information on an international basis.
Worldwide
4 Nov 2014
17
IRS Offers FATCA Relief, Extending Registration Deadline And Expanding Intergovernmental Agreement List
On April 2, 2014, the U.S. Internal Revenue Service issued Announcement 2014-17, which provides certain FATCA relief.
United States
16 Apr 2014
18
Official Confirms IRS Review Of Community Benefit Compliance By 3,377 Hospitals
An IRS official confirmed, while speaking at an American Health Lawyers Association conference on October 16th, that the IRS has identified 3,377 tax-exempt hospitals that are being reviewed for compliance with the tax exemption community benefit standard.
United States
26 Oct 2012
19
IRS Posts Draft Revised Withholding Forms Conforming To FATCA
The U.S. Internal Revenue Service has posted draft versions of revised Form W-8BEN.
United States
15 Jun 2012
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