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Tax Liability › Beneficial Owner

McDermott Will & Schulte

Economic Ownership of Shares Transferred as Collateral

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Dividends from shares are taxable for shareholders, even if the dividends do not remain with them economically. This (not entirely new) finding can be gleaned from a recent Federal Fiscal Court (BFH) ruling in which the...more

Rivkin Radler LLP

Tax Compliance: Self-Assessment, Transparency, and Enforcement

Rivkin Radler LLP on

NY’s Almost There- Back in June of this year, New York’s legislature passed a bill that, if enacted, would create the first state-level public database with information regarding the ownership of limited liability...more

Warner Norcross + Judd

Shared Ownership of Family Cottages, Part Two: Ownership Structures for Shared Family Property

Warner Norcross + Judd on

In my last post about shared ownership of cottages, I discussed items to consider when deciding whether to create a plan for future generations to share the ownership and use of the family cottage or vacation property. Once...more

Bilzin Sumberg

FinCEN Prepares ID Application for Tracking CTA Beneficial Ownership

Bilzin Sumberg on

On January 17, 2023, the Financial Crimes Enforcement Network (FinCEN) published a notice seeking public comment on the application that will be used by individuals to obtain a unique FinCEN Identifier (a “FinCEN ID”),...more

Freeman Law

FDAP Income

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The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...more

Hogan Lovells

Identificación del Beneficiario Controlador como nueva obligación fiscal

Hogan Lovells on

A partir de 1 de enero de 2022 las entidades legales en México deberán implementar procedimientos internos para obtener y conservar, como parte de los registros contables, la información de sus Beneficiarios Controladores....more

Hogan Lovells

Identification of the Beneficial Controller as a new tax liability

Hogan Lovells on

Effective January 1, 2022, legal entities in Mexico must implement internal procedures to obtain and keep, as part of the accounting records, the information of their Beneficial Controllers....more

Freeman Law

What is a REIT? Real Estate Investment Trusts and Taxation

Freeman Law on

REITs, or real estate investment trusts, are often described as a mutual fund for real estate.  Congress established REITs to allow individual investors to invest in large-scale, income-producing real estate. Since their...more

McDermott Will & Schulte

Finding John Doe: IRS Steps up Enforcement Efforts to Take the Anonymity Out of Virtual Currency

McDermott Will & Schulte on

The Internal Revenue Service (IRS) is stepping up its virtual currency enforcement, and taxpayers who have engaged in a cryptocurrency transaction should immediately assess any potential tax implications as the IRS has...more

Conyers

Tax and the British Virgin Islands: Separating Myth From Reality

Conyers on

We will begin with an overview of the tax position. The British Virgin Islands has no corporate tax, capital gains tax, wealth tax, or any other tax applicable to a British Virgin Islands company. These companies are exempted...more

White & Case LLP

German IP Withholding Tax

White & Case LLP on

On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more

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