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Corporate Restructuring Tax Liability

Latham & Watkins LLP

Restructuring Plans and Tax Liabilities A More Assertive HMRC

Latham & Watkins LLP on

Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more

Cadwalader, Wickersham & Taft LLP

Entity Conversion Under State Law Is Not a Modification of Debt

After almost 20 years, the IRS has again ruled that the conversion under state law of a limited liability company (LLC) disregarded for tax purposes to a corporation did not result in a “significant modification” of the...more

White & Case LLP

Spain to tax acquisitions of shares of major Spanish listed companies

White & Case LLP on

The Spanish Official Gazette published last October 16th legislation enacting a new indirect Tax on Financial Transactions levied, at 0.2%, on the acquisition of shares of major Spanish listed companies irrespective of the...more

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