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Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more
The new UK fund vehicle Reserved Investor Fund (RIF) is available beginning today, 19 March 2025. The RIF is available for all investment strategies, but what might make it an appealing option, particularly certain tax...more
On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to...more
The Chancellor of the Exchequer, Rachel Reeves, delivered her first Budget Statement on 30 October. The Autumn Budget drew widespread attention, with several measures grabbing the headlines, including the historic fact that...more
Rachel Reeves, the first female Chancellor of the Exchequer in the role’s 800-year history, delivered Labour’s first budget in 14 years on the 30th October. We have set out below a brief summary of some of the tax measures...more
Yesterday, 30 October 2024, the Chancellor announced that the Autumn 2024 budget will raise taxes by £40bn, the biggest raise since 1993. While the Autumn budget arguably does not portray as pessimistic an outlook for...more
As part of the Autumn Statement, the UK government on 30 October 2024 announced a reform of its taxation of carried interest. This follows a call for evidence on the reform of the UK taxation treatment of carried interest in...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2024 on 30 October 2024. The Budget was the first to be delivered by the new Chancellor of the Exchequer, following the election of the Labour...more
The real estate sector was not ignored by Budget announcements today. There were no seismic changes – the changes announced were less impactful than the speculation in the weeks preceding the Budget....more
Guernsey companies are extremely popular, and are used for a wide variety of purposes. Guernsey companies can be incorporated quickly and a large number of corporate services providers offer day-to-day administration...more
Businesses in the blockchain and cryptoasset space are increasingly looking to utilise digital currency and other cryptoassets as an alternative to or alongside other, more traditional employee incentive arrangements, such as...more
In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more
Following the UK Government’s 6 March announcement of tax reforms for the current “non-dom” tax regimes, the opposition Labour party has begun to outline how its plans would differ if they win the next UK general election. In...more
As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more
Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more
The United Kingdom has long been a target destination for activist investors. It is the venue for nearly half of all of recent activist campaigns in Europe. In previous articles, we have discussed how informed boards should...more
The UK tax legislation imposes an “exit tax charge” on the unrealised capital gains of a company which migrates from the UK. The exit of a taxpayer (or their assets) is generally the last point in which a taxing jurisdiction...more
Recent publicity around the UK taxation of carried interest may, in due course, make it more likely that a UK government would look again at the tax rules around carried interest. ...more
Welcome to May’s edition of our UK Tax Round. This month has been relatively quiet but there were a couple of cases that affect transactions that we see in practice, including an interesting update on what could constitute a...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more
Unexpectedly, it is likely the changes to the Luxembourg-UK double tax treaty will not be effective until 2024 at the earliest. Where that is the case, some Luxembourg investors in UK property rich entities will have another...more
Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more
More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more
The UK and Luxembourg have renegotiated their double tax treaty. The new treaty has been published, but is not yet in force. Significant changes have been made to the capital gains tax article amongst other provisions....more