News & Analysis as of

Tax Reform Tax Liability Financial Services Industry

King & Spalding

“Revenge Tax”

King & Spalding on

Withholding Tax Rules Under Current Law - Current US tax law provides for a 30% withholding tax on interest paid by a US borrower to foreign lenders. However, many foreign lenders are exempt from this tax, either under the...more

Goodwin

UK Government announces update on new carried interest tax regime

Goodwin on

On June 5, 2025, the UK Government announced the result of their recent consultation process regarding their plans to bring carried interest within the income tax regime from April 2026, subject to an effective tax rate of...more

DLA Piper

REIT Tax News - June 2025

DLA Piper on

On May 22, 2025, the House of Representatives passed a tax bill (House Tax Bill) that proposes to make permanent – and increase – the section 199A deduction for ordinary REIT dividends to 23 percent. This change would reduce...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Katten Muchin Rosenman LLP

The Salaried Members Rules and the 'Significant Influence' Test – Does the BlueCrest Case Affect Me (As a Partner) or My Firm?

Salaried Members Rules - Limited liability partnerships or "LLPs" are common corporate vehicles utilised by the financial services sector to establish UK investment management operations and other financial businesses and,...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Cadwalader, Wickersham & Taft LLP

Finalized Treasury Regulations Require Disclosure of Certain Micro-captive Transactions

On January 14, 2025, Treasury and the IRS published final regulations (the “Regulations”) that identify certain micro-captive insurance transactions, as well as transactions substantially similar thereto, as either listed...more

Cadwalader, Wickersham & Taft LLP

UK Government Considering Expansion of Investment Transactions List to Include Crypto-Assets

The UK Government has announced a public consultation regarding the possible expansion of the UK’s investment manager exemption (“IME”) to encompass crypto-assets. The IME enables UK-based fund managers to provide...more

Kohrman Jackson & Krantz LLP

New Tax Rule Changes Reporting Requirements For Venmo, Paypal, Cash App

A new tax rule will see the Internal Revenue Service (IRS) gain information on income small businesses receive via transactions on popular payment applications. As of Jan. 1, 2022, businesses that accept more than $600 per...more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

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