Maryland's Sales Tax on IT and Data Services
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5 Key Takeaways | Artificial Intelligence: What Tax Professionals Need to Know
Avoiding Tax Consequences During Oil & Gas Restructurings
The UK tax regime for carried interest is being substantially revised from April 2026. This Alert focuses on one particular aspect: the changes to how credit funds should calculate the average holding period (AHP) of their...more
Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment returns, while offsetting...more
On 24 July 2025, the Luxembourg government introduced Bill No. 8590 (the Bill), which proposes a new competitive carried interest tax regime with the stated objectives being: to create a legal framework that fosters the...more
On 24 July 2025, a draft bill (the Bill) proposing significant amendments to the law of 4 December 1967 on income tax and the law of 12 July 2013 on alternative investment fund managers (AIFMs) was submitted to the Luxembourg...more
Fund secondaries transactions have grown enormously over the last 20 years or so. Recently, funds have been under pressure to return capital to investors in the context of a range of market constraints on traditional exit...more
Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more
On 21 July 2025, the UK Government published draft legislation for the new UK carried interest regime, which is expected to come into effect from 6 April 2026. As previously announced, the draft legislation provides for...more
On 21 July 2025, the UK government published draft legislation relating to its new carried interest regime. This Client Alert considers key aspects of the new regime and how it may apply to UK-based asset managers and non-UK...more
Each entity incorporated, established or registered in the Cayman Islands must file an annual economic substance notification with the Tax Information Authority (the "TIA"). A "relevant entity" conducting "relevant...more
President Donald J. Trump signed the legislation commonly known as the “One Big Beautiful Bill” (Tax Act) into law on July 4, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management...more
As we power through what remains of this quarter, working to get deals closed before quarter end next week, you may have noticed some additional (and new!) blacklining in the tax section of your credit agreement thanks to a...more
Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more
On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more
On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more
On May 22, 2025, the House of Representatives passed a tax bill with some limited amendments (House Tax Bill). The House Tax Bill will now head to the Senate, where additional amendments could be made. Below, we outline five...more
Over the past 25 years, the Cayman Islands have established themselves as a leading jurisdiction for alternative investment funds, with nearly 13,000 regulated open-ended funds and over 17,000 regulated closed-ended funds. As...more
On 28 April 2025, the UK government published draft legislative amendments to: - Align the UK’s domestic tax rules on permanent establishments (PE) with the 2017 Organisation for Economic Co-operation and Development (OECD)...more
Welcome to April’s edition of our UK Tax Round Up. While this month has been quiet on the case law front, there have been a number of HMRC announcements and updates to prior published guidance along with published responses...more
On 28 April, the UK Government produced draft legislation for consultation as the latest step in the reform of UK rules on transfer pricing, permanent establishments and diverted profits tax. From an asset management...more
The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more
During the last decade, the shape and source of capital flows and investment have fundamentally shifted. Private capital continues to flow into all asset classes including real estate, infrastructure, private credit, and...more
Introduction - After a long gestation, the much heralded new UK fund structure, the Reserved Investor Fund (“RIF”) is finally expected to be available from 19 March 2025....more
On January 8, 2025, the staff (Staff) of the Securities and Exchange Commission’s (SEC) Division of Investment Management (IM) released the 2025 Names Rule FAQs (2025 FAQs) related to the amendment of Rule 35d-1 (Names Rule)...more
Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more
As the end of 2024 draws to a close, Luxembourg aims to introduce an interesting technical update that may globally be of interest for our clients with structures in Luxembourg. On 11 December 2024, the Luxembourg...more