Imminent Shift: Preparing for the T+1 Settlement Impact on Equity-Based Compensation — The Consumer Finance Podcast
Navigating the Once-Obscure German Nonresident Withholding Tax
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Cum-Ex Dividend Trade Investigations
When an employer (or the proper withholding agent, like a plan administrator) issues a retirement benefit, there is generally an obligation to withhold income tax on the payment and to report the payment on Form 1099-R....more
Revenue Ruling 2025‑15 (available here) provides guidance on withholding and reporting obligations when a plan participant or beneficiary fails to cash a distribution check and a replacement check is issued. As discussed...more
The IRS has released Revenue Ruling 2025-15, which clarifies the federal tax withholding and reporting responsibilities of retirement plan administrators when a distribution check is issued but remains uncashed and a...more
The One Big Beautiful Bill Act (the “Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...more
On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...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
In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more
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
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice...more
Puerto Rico has recently relaxed its requirements for remote work, implementing significant changes. The first set of changes occurred in 2022 with the enactment of Law 52-2022....more
If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more
Welcome to the December 2024 edition of our UK Tax Round Up. This month has seen interesting decisions on the basis for rescission of an arrangement with adverse tax consequences, the treatment of a loan from an EBT, the tax...more
Types of business entities - The most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”), the corporation (“Sociedad Anónima” or “SA”)...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 4, 2024 – November 8, 2024...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more
The Australian government has, nearly 12 months after announcing them, released draft legislation to implement two key income tax incentives for build-to-rent (BTR) projects: Extending the 15% withholding tax for foreign...more
Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises. The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more
The Government of the Kingdom of Saudi Arabia (“Kingdom”) in February 2021 announced its objective to limit governmental contracting with multinational companies (“MNCs”) that do not have a Regional Headquarter (“RHQ”) in the...more
1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the...more
TYPES OF BUSINESS ENTITIES - In the Netherlands, there is a distinction between entities which qualify as legal entities (‘rechtspersonen’) and partnerships (‘personenvennootschappen’) which do not. Legal entities are...more
1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more
1. Types of Business Entities - The currently available local corporate structures for conducting business are: - General partnership - Limited partnership - Limited liability company - Joint-stock company -...more
Now that the 2023 tax filing season is underway, many taxpayers are having an unpleasant surprise when they file their tax return this year and find out they are getting a much smaller refund than they were expecting, or...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER UKRAINIAN LAW - І. Types and specifics of real estate in Ukraine - The main types of real estate in Ukraine are the following: • plots of land; • other objects...more