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Cadwalader, Wickersham & Taft LLP

Is Revenge a Dish Best Served Under the Tax Code?

Among the myriad provisions of the budget bill that passed the U.S. House of Representatives last month, one that has recently gained increased prominence in recent weeks is proposed Section 899, increasingly referred to as...more

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

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Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

Conyers

Economic Substance Declaration Filings – May 2025

Conyers on

The Economic Substance Act 2018 (the “Act”) requires Bermuda-based entities that are carrying on a “relevant activity” in a relevant financial period and entities claiming “non-resident entity” status under the Act to file an...more

Eversheds Sutherland (US) LLP

House passes the One Big Beautiful Bill Act with minor revisions to the international tax provisions

On May 22, 2025, the House of Representatives voted along party lines (with one Republican member voting present and two Republican members not voting) to advance the “One Big Beautiful Bill” Act (the OBBB) to the Senate for...more

A&O Shearman

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

A&O Shearman on

On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax: Trump Exits Global Tax Deal and Freezes Green Energy Funds

Since assuming office on January 20, 2025, President Donald Trump has prioritized tax policy, issuing a series of directives aimed at boosting economic growth and advancing the “America First” agenda. On his first day in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Possible Tax Reforms Could Run Up Against Deficit and Debt Concerns

Key Points - - Many of the tax reform suggestions President-elect Trump floated during the campaign would result in significant revenue loss, which could mean they will face resistance from Republicans concerned about...more

Conyers

Cayman Entities and the Economic Substance Regime – Is Your Cayman Entity in Compliance?

Conyers on

As we gear up for the final quarter of 2024, this is an excellent time to review Cayman based entities with a financial year end of 31 December 2024 and consider the position of these entities with respect to the Cayman...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Rep. Darin LaHood, R-IL

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy debates in Congress. In this episode of “The Cloakroom with Peter Roskam,”...more

Conyers

Economic Substance Regime Overview

Conyers on

The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...more

Conyers

BVI Quarterly Corporate Update Q1 2024

Conyers on

Welcome to the first edition of our Quarterly Corporate Update for 2024 covering recent developments in the British Virgin Islands. The first quarter of 2024 saw continued strong activity in the BVI office. Our corporate...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

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

Conyers

British Virgin Islands Removed from EU Tax Blacklist

Conyers on

Following a meeting of the Council of the European Union on 17 October 2023, the British Virgin Islands (“BVI”) was removed from the EU list of non-cooperative jurisdictions for tax purposes (Annex I), the EU’s so-called...more

Stikeman Elliott LLP

Tax Base Erosion: Canada Responds with Draft EIFEL Rules Legislation

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On August 4, 2023, the Department of Finance released an updated version of the draft legislation that will incorporate the excessive interest and financing expense limitation rules (“EIFEL Rules”) into the Income Tax...more

Stikeman Elliott LLP

Clean Energy Incentives: August 4, 2023 Legislative Proposals Relating to the Income Tax Act and Regulations

Stikeman Elliott LLP on

On August 4, 2023, the Department of Finance of Canada released significant legislative proposals relating to the federal government’s proposed measures to grow Canada’s clean economy. The release includes the draft...more

Walkers

Guernsey Guide: legal, regulatory, transparency and supervisory framework

Walkers on

This briefing explains Guernsey’s adoption of rigorous international tax and regulatory standards, which, in conjunction with its local tax law, make it an ideal location for investment funds and other investment vehicles....more

Hogan Lovells

Vorsicht ist besser als Nachsicht! Die grunderwerbsteuerlichen Anzeigepflichten beim Share Deal

Hogan Lovells on

Das Jahressteuergesetz 2022 (JStG 2022) brachte verschärfte Rechtsfolgen bei Missachtung der vorgegebenen Anzeigepflichten bei Grundstücksveräußerungen mittels Übertragung von Anteilen an einer Kapitalgesellschaft („Share...more

Cadwalader, Wickersham & Taft LLP

EU Directive Targets 'Shell' Companies

On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of “shell” entities for tax purposes. The draft of the Directive proposes a common minimum substance test...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Proskauer Rose LLP

UK Tax Round Up - December 2021

Proskauer Rose LLP on

UK Case Law Developments - Taxpayer treated as receiving distribution in tax avoidance case - We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more

Proskauer Rose LLP

UK Tax Round Up - October 2021

Proskauer Rose LLP on

The Chancellor presented the Budget on 27 October. Although it contained a wide range of general spending and tax-related announcements, there was nothing of significance for the private funds industry that had not been...more

Proskauer Rose LLP

UK Tax Round Up - July 2021

Proskauer Rose LLP on

In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more

Morgan Lewis

Initial Takeaways from the American Jobs Plan

Morgan Lewis on

The Biden-Harris administration announced its American Jobs Plan, a legislative framework laying out an ambitious $2 trillion investment in physical and human infrastructure, on March 31. The bulk of the proposed spending is...more

Foster Garvey PC

Online Travel Update: Accor and Marriott’s interest in short-term rental interest grows; new tax claims filed against OTAs in...

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This week’s Update features a heavy dose of short-term rentals as the long-awaited Airbnb IPO finally arrives and many hoteliers seek to capitalize on growing (COVID-induced) traveler demand in this segment. Enjoy....more

Womble Bond Dickinson

US Treasury Leadership Gives Direction to the OECD Digital Tax Project in January 29 Note

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OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more

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