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Mintz - Tax Viewpoints

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

Mintz - Tax Viewpoints on

Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

Cadwalader, Wickersham & Taft LLP

Hargreaves Property : What Does the Latest Decision Mean for UK Withholding Tax?

Cadwalader, Wickersham & Taft LLP on

In many respects, the Upper Tribunal’s decision in Hargreaves Property will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to UK...more

Akin Gump Strauss Hauer & Feld LLP

Upper Tribunal Overturns Decision on Tax Treatment of Management Fee Rebates

Akin Gump Strauss Hauer & Feld LLP on

The Upper Tribunal (UT) has found that amounts paid by Hargreaves Lansdown (HL) (an investment platform service provider) to its customers, which represented rebates received from investment fund managers, were “annual...more

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