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Proskauer Rose LLP

UK Tax Round Up - January 2024

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Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...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

Freeman Law

International Tax Treaty: China

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Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Freeman Law

International Tax Treaty: Canada

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Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

Proskauer Rose LLP

UK Tax Round Up - April 2020

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Temporary changes to the statutory residence test for inbound COVID-19 workers - The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more

Bennett Jones LLP

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

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On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more

Proskauer Rose LLP

UK Tax Round Up - January 2020

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UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2018 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more

Bracewell LLP

Bracewell Tax Report - September 2018 #2

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Proskauer Rose LLP

UK Tax Round Up - April 2018

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General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more

Foley & Lardner LLP

Tax Cuts and Jobs Act – New Compensation Tax for Non-Profit Organizations on Excess Compensation and Excess Parachute Payments

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The Tax Cuts and Jobs Act passed late last year and became effective as of January 1, 2018. The Act includes a new provision that subjects certain “excess compensation” paid by exempt organizations (organizations exempt from...more

Foster Garvey PC

Tackling Tax Reform – Part IV: What Can We Expect To See

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On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 8

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

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