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Capital Gains Tax Income Taxes

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: An Overview of Incentive Stock Options (ISOs)

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This article is the third in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part X – Converting a...

Foster Garvey PC on

When considering converting a C corporation to an S corporation, tax advisers and taxpayers need to pay careful attention to the many perils that exist. Failure to pay close attention to the road in this area could result in...more

Farella Braun + Martel LLP

Taxation of Realized, but Undistributed, Gains or (What Moore Means)

The Wall Street Journal, following the Supreme Court's decision in Moore v. United States, claims that the five-justice majority opinion “open[s] the door to taxing unrealized gains.” Query whether the Moore decision simply...more

Foster Garvey PC

The Newest Chapter in the Tumultuous Journey of the Washington State Capital Gains Tax – Judge Allyson Zipp Rules From the Bench

Foster Garvey PC on

As reported last week, opponents of the Washington state capital gains tax, after ultimately losing in the courts to have the legislation stricken as unconstitutional, decided to take the matter to the voters. They have...more

Foster Garvey PC

The Tumultuous Journey of the Washington State Capital Gains Tax Continues

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I have reported in several prior blog posts the significant events impacting the newly enacted Washington state capital gains tax. The turbulent ride of this legislation continues!...more

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

K&L Gates LLP

Doing Business in Australia

K&L Gates LLP on

Australia welcomes new business and foreign investment by providing a strong economy, a stable political environment and a skilled and talented workforce. Our comprehensive guide to Doing Business in Australia has been...more

Venable LLP

Earnouts and Their Tax Treatment

Venable LLP on

As buyers and sellers engage in negotiations for the sale of a business, often there may be disagreements as to the value and expected growth of that business. One party might currently value the business higher than the...more

Proskauer - Tax Talks

Change to non-domicile tax regime forms part of UK Spring Budget 2024

Proskauer - Tax Talks on

As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more

Morgan Lewis

UK Sovereign Immunity from Direct Taxation

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Sovereign immunity is a principle of public international law whereby one sovereign state should not seek to apply its law to another sovereign state. Alongside the jurisdictional immunity foreign sovereigns enjoy in the...more

International Lawyers Network

Establishing a Business Entity in Spain (Updated)

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

International Lawyers Network

Buying and Selling Real Estate in England and Wales (Update)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Davidoff Hutcher & Citron LLP

If It's Too Good To Be True...The Latest Guidelines from the IRS

There are a lot of very smart tax attorneys out there who are trying to figure out something new, and yet there’s very little innovation.  Almost all techniques that we use are incremental variations of an older technique...more

International Lawyers Network

Establishing a Business Entity in Austria (Updated)

1. Introduction - In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability...more

International Lawyers Network

Establishing a Business Entity in Argentina (Updated)

Types of business entities - The two most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”) and the corporation (“Sociedad Anónima” or...more

Allen Barron, Inc.

Estate and Tax Planning for US Expatriates

Allen Barron, Inc. on

What are the most important elements of estate and tax planning for US expatriates?  Are you planning to move out of the United States?  Are you a US taxpayer who lives and works outside of the country?  What are some of the...more

Allen Barron, Inc.

Tax Tips for Lottery Winners

Allen Barron, Inc. on

Today is the anniversary of the largest Powerball lottery victory in the United States of $2.04 billion.  Just over the $1.765 billion jackpot claimed last month (Oct 2023).  What are some tax tips for lottery winners and...more

Bowditch & Dewey

Massachusetts Tax Reform Enacted – Estate Tax Exemption Increase and Other Help for Residents

Bowditch & Dewey on

The long-awaited Massachusetts tax reform package was signed by Governor Maura Healey on Wednesday, October 4, 2023. Among the provisions: Estate Tax Reform: Establishes a non-refundable credit of $99,600 for each estate,...more

Blake, Cassels & Graydon LLP

Propositions législatives du 4 août 2023 : Présentation de certaines mesures fiscales

Le 4 août 2023, le ministère des Finances (le « ministère ») a publié de multiples propositions législatives et notes explicatives connexes (les « propositions du 4 août »). Ces propositions du 4 août comprennent des...more

Blake, Cassels & Graydon LLP

2023 August 4 Draft Legislation: Selected Tax Measures

On August 4, 2023, the Department of Finance (Finance) released a significant package of draft legislative proposals and related explanatory notes (August 4 Proposals). The August 4 Proposals include updated legislative...more

Partridge Snow & Hahn LLP

Gifts of Privately Held Company Interests to a 501(c)(3) Public Charity

Donors with ownership interests in privately held companies (i.e., limited liability companies, corporations, partnerships) have the ability to utilize the interest to make a charitable gift. This strategy becomes...more

K&L Gates LLP

BTR Series Part 2: Getting the Tax Right—Australian Income and Capital Gains Tax

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As trailed in Part 1 of our build to rent (BTR) series, the Australian Government has announced plans to remove some of the key income tax barriers to BTR projects. In this Part 2, we take a closer look at those plans (and...more

Blank Rome LLP

NFTs: A Tale of Two Classifications

Blank Rome LLP on

On March 21, 2023, the Department of the Treasury and the Internal Revenue Service (“IRS)” released Notice 2023-27, announcing their intent to provide guidance on classifying certain non-fungible tokens (“NFTs”) as...more

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