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Investment International Tax Issues

Levenfeld Pearlstein, LLC

Establishing Your Financial Presence Outside the United States: A Strategic Guide

High-net-worth individuals and families contemplating diversifying their wealth beyond U.S. borders, also known as outbound wealth planning, may be motivated by concerns about domestic political developments, economic policy...more

Seyfarth Shaw LLP

Hong Kong Launches Company Re-domiciliation Regime

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In a move to enhance Hong Kong’s status as a global business and financial hub, and to attract foreign companies to take advantage of Hong Kong’s taxation system and professional services–thereby encouraging investment and...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of May 26, 2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

Walkers

Moving to the Channel Islands: A guide for asset managers

Walkers on

Jersey and Guernsey have long been recognised as leading international investment hubs, offering asset managers a compelling mix of professional and lifestyle advantages....more

McDermott Will & Schulte

Exit tax for investement shares

Anyone who moves out of Germany and has investment shares or transfers them outside of Germany will have to pay taxes – even if the shares are not sold. Private investors in investment funds will have to pay taxes in the...more

Morgan Lewis

Government Draft of Annual Tax Act 2024 Adopted

Morgan Lewis on

The Federal Cabinet adopted the government draft of an Annual Tax Act 2024 (JStG 2024) on June 5, 2024. The government draft largely corresponds to the draft bill of May 17, 2024 and contains a large number of very different...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

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Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Mayer Brown

Public Notice for Adhesion to Tax Settlement: Tax debts Related to Subsidies for Investments

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On May 16, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) and the Office of Attorney-General of the National Treasury (“PGFN”) jointly published the Public Notice of Transaction for Adhesion in the Tax...more

Jones Day

Dispute Resolution Under OECD’s “Pillar Two” 15% Global Minimum Tax Remains Unclear

Jones Day on

In October 2020, the Organization for Economic Co-operation and Development (“OECD”) Secretariat released a report addressing its “Pillar Two” blueprint for an overhaul of the international tax system. Pillar Two provides for...more

Mayer Brown

Brazil’s New Tax Rules for Infrastructure Investments

Mayer Brown on

Below we list some key tax legislative changes that are relevant to new investments in infrastructure projects and that are already in force or have been announced by the government and are under discussion in the National...more

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

Allen Barron, Inc. on

Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Hogan Lovells

Changes under the Future Financing Act – Employee equity finally future-proof?

Hogan Lovells on

With the recently published draft of a "Future Financing Act", the federal government has reacted to the criticism on the tax treatment of equity instruments granted to employees. From the perspective of young companies, the...more

Hogan Lovells

Änderungen durch das Zukunftsfinanzierungsgesetz – Mitarbeiterbeteiligung endlich zukunftsfest?

Hogan Lovells on

Mit dem kürzlich veröffentlichten Entwurf eines „Zukunftsfinanzierungsgesetzes“ hat die Bundesregierung auf die Kritik zur steuerlichen Behandlung von Mitarbeiterbeteiligungen reagiert. Die vorgesehenen Änderungen sind aus...more

Skadden, Arps, Slate, Meagher & Flom LLP

Exploring Potential Investor-State Treaty Challenges to the OECD’s Pillar Two Model Tax Rules

Adoption of the OECD Pillar Two model rules implementing accords on a global minimum corporate tax rate may result in anomalous or unfair results for some multinationals. Protections available under investment treaties,...more

Proskauer - Tax Talks

HMRC Clarifies Application of QAHC Regime to Corporate Lending Vehicles

Proskauer - Tax Talks on

HMRC has recently updated the guidance relating to the UK’s new qualifying asset holding company (QAHC) tax regime which was introduced from 1 April 2022. The new guidance clarifies HMRC’s approach to whether corporate...more

McDermott Will & Schulte

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Cadwalader, Wickersham & Taft LLP

OECD Cryptoasset Reporting Framework

On 22 March 2022, the Organisation for Economic Co-operation and Development (“OECD”) published a public consultation document proposing new and amended reporting requirements with respect to cryptoassets and electronic-money...more

Orrick, Herrington & Sutcliffe LLP

Bilancio di Previsione dello Stato per l'anno finanziario 2020

(Legge 27 dicembre 2019, n. 160 pubblicata in Gazzetta Ufficiale serie generale 304 del 30 dicembre 2019). ...more

Faegre Drinker Biddle & Reath LLP

Leveraged Acquisitions Roundtable

Drinker Biddle’s Corporate and Securities Group recently hosted its 13th annual roundtable discussion, which took place at Gulph Mills Golf Club in King of Prussia, Pennsylvania. This year’s event sported a new name—“The...more

Orrick, Herrington & Sutcliffe LLP

The Simple Investment Company - A New Structure for the Investment and Financial Support to Italian SMEs

In recent years, in Italy a constant growth in investments to emerging Italian companies (i.e. the "start-ups") has taken place. ...more

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