The Chancellor of the Exchequer delivered the United Kingdom (UK) Spring Budget for 2024 on 8 March 2024. The Budget was delivered against the backdrop of an anticipated general election in the summer or autumn of 2024 and...more
Is the unitary business principle the sole test for determining whether a state can tax an apportioned share of a non-domiciliary’s capital gains under the U.S. Supreme Court’s Due Process Clause and Commerce Clause...more
New York Diaspora? Like most every other state in the Union, New York has experienced its share of fiscal stress over the last few decades. The source or cause of its problems? Well, that may depend upon the respondent to...more
As the ongoing COVID-19 pandemic continues to wreak havoc on global financial markets, adversely impacting many currency exchange rates, many non-US persons may view the United States as a safe haven or ripe for opportunistic...more
In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more
Following on from the UK Chancellor’s speech last month, draft legislation was published on 5 December 2016 setting out how the Government intends to stimulate investment in the UK. The Finance Bill (the Bill) is subject...more
Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more
The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more