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Capital Markets › Tax Liability

Ropes & Gray LLP

Duty-Free: The New UK Single Tax on Securities

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The replacement of the UK’s paper-based stamp duty (SD), and its electronic cousin stamp duty reserve tax (SDRT), with a unified and modernised single tax on securities transactions re-emerged this week as a Government...more

Levenfeld Pearlstein, LLC

PTET in Private Equity Accounting Deals in 2025 and Beyond?

Levenfeld Pearlstein, LLC on

In connection with the first Trump administration’s tax bill known as the Tax Cuts and Jobs Act (“Jobs Act”), a cap on state and local tax deductions was instituted at $10,000 (“SALT Cap”) for tax years 2018 through 2025. The...more

Holland & Knight LLP

IRS Releases Final Regulations on Reissuance and Retirement of Tax-Exempt Tender Option Bonds

Holland & Knight LLP on

The IRS released on Dec. 30, 2024, final regulations on Sections 1.150-3 and 1.1001-3(a)(2) (the Regulations) regarding the reissuance and retirement (debt extinguishment) of tax-exempt tender option bonds....more

Cole Schotz

The 2025 Tax Appeal Review

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Continued pressures created by elevated levels of mortgage interest rates, vacancies, as well as stricter lending policies, point to higher capitalization rates, lower property values and tax appeal opportunities in 2025....more

Crunched Credit

Time to Fix REMIC:  Grand Bargain Part II

Crunched Credit on

Last week I talked about the Grand Bargain to fix our business. If we’re fixing to fix our business now, we’ve got to talk REMIC. The Real Estate Mortgage Investment Conduit (REMIC) created as part of the Tax Reform Act of...more

Conyers

Bermuda Corporate Income Tax and the Shipping Income Exclusion

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In a landmark move on 27 December 2023 the Bermuda Government took a significant step by adopting the Corporate Income Tax Act 2023 (the “CIT Act”), a pivotal piece of legislation that promises to reshape the island’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

Skadden, Arps, Slate, Meagher & Flom LLP on

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more

Stikeman Elliott LLP

Canada’s Proposed Share Buyback Tax

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On August 4, 2023, the Department of Finance released a revised version of its proposed 2% equity buyback tax (“Buyback Tax”) that will apply to relevant transactions that occur on or after January 1, 2024....more

Woodruff Sawyer

1% Excise Tax, SPACs, and Independent Director Personal Liability: The Rock and the Hard Place

Woodruff Sawyer on

Being stuck between the choice of either disappointing investors or facing potential personal liability is the very definition of being caught between a rock and a hard place. Tax liability insurance can take you to a more...more

Hogan Lovells

Real estate securitisations: guidance by Italian tax authorities on the applicable tax treatment

Hogan Lovells on

With ruling No. 132 of 2 March 2021 (the “Ruling”), the Italian Tax Authorities (“ITA”) provided clarifications on the tax regime applicable to real estate special purpose companies (the “RE SPVs”) carrying out securitisation...more

WilmerHale

German Cum/Ex-Trades: Enhanced Risks and Industry-Wide Challenges

WilmerHale on

The German and international financial industries and their advisors have come under new pressure to investigate so-called 'cum/ex' trades conducted between 2000 and 2012. For many years, tax authorities and criminal...more

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