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
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
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
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
Transactions involving the disposition of a U.S. real property interest (“USRPI”) by a foreign person (i.e., a nonresident alien individual or foreign entity, the seller) are subject to the Foreign Investment in Real Property...more
This is the third part of a series covering certain securities law, corporate governance, and tax considerations related to stock options and restricted stock unit (RSU) awards granted by public companies....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
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 New York State Bar Association Tax Section (the “NYSBA”) has asked the government to provide guidance on the procedure for filing a protective return in respect of withholding tax in response to YA Global Investments, LP...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
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
Nearly six months after it was passed — with overwhelming support — by the New York Legislature, Governor Kathy Hochul recently signed Assembly Bill A6040, or the Freelance Isn’t Free Act (the “Act”). With an effective date...more
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...more
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
As new college graduates cross the stage to receive their diplomas, many will also be heading to their first full-time jobs. There are some tax tips new graduates can implement early on that will help with savings in the long...more
One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more
During the 2022 tax filing season, many taxpayers had an unpleasant surprise when they filed their tax return and found out they were getting a much smaller refund than they were expecting, or worse, had a balance due....more
Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more
Income tax effects are often the last thing on one’s mind when going through a divorce, but having sound tax advice during a divorce is important for many reasons. FILING STATUS - Divorce will change your income tax...more
Exempt Payments to Non-Resident Aliens and Federal Withholding - Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions. Wages paid to...more
Withholding on Foreign Payments of FDAP - Income A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. ...more
Even without a German nexus, in cases of a licensing of right registered in Germany an application/disclosure before 30 June 2022 might be necessary. ..According to the German Federal Ministry of Finance (BMF) the...more
The pay and refund mechanism introduced in 1 January 2019 to Polish CIT, effectively suspended until the end of 2021, after amendments, came into force from and including 1 January 2022. ...more
Ordinarily, taxpayers file their income tax returns each year with the IRS and hear nothing more. Rather, the Internal Revenue Service (“IRS”) simply processes the tax return, assesses the reported amount of tax due, and...more
COVID has not only seen a migration of employees to remote work but has created a new business model that is here to stay. In the midst of COVID, employers were eager to allow their employees to work from home and maintain a...more