News & Analysis as of

Organization for Economic Co-operation and Development Capital Gains

Rivkin Radler LLP

Tax Authorities of the World Unite? Not Quite, But the IRS Joins the Movement to Tax the Rich

Rivkin Radler LLP on

Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more

Dechert LLP

New Luxembourg-UK Double Tax Treaty Will Introduce Key Changes Including Access to Treaty Benefits for CIVs / Investment Funds

Dechert LLP on

Following the Luxembourg parliament’s ratification of the new Luxembourg-UK double tax treaty (“DTT”) on 19 July 2023, the new DTT should take effect in 2024. The UK ratified the new DTT on 7 June 2022....more

Davies Ward Phillips & Vineberg LLP

Government of Canada Releases Package of Proposed Domestic and International Tax Legislation

The Department of Finance (Finance) released draft tax legislation for public consultation on August 4, 2023, with a stated focus on promoting tax fairness and a clean economy. The most significant item released is the...more

Proskauer Rose LLP

UK Tax Round Up - March 2023 - 2

Proskauer Rose LLP on

Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

Proskauer Rose LLP

UK Tax Round Up - November 2022

Proskauer Rose LLP on

Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more

A&O Shearman

The new Luxembourg/United-Kingdom tax treaty has been signed.

A&O Shearman on

More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more

Goodwin

The UK and Luxembourg Signed A New Double Tax Treaty

Goodwin on

On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Bennett Jones LLP

Supreme Court of Canada Upholds Treaty-Based Canadian Holding Structure

Bennett Jones LLP on

On November 26, 2021, the Supreme Court of Canada (the SCC) released its highly anticipated decision in Canada v Alta Energy Luxembourg SARL, 2021 SCC 49 [Alta Energy Lux], that addressed treaty-based holding structures and...more

Davies Ward Phillips & Vineberg LLP

Top Court Blesses Treaty-Shopping Arrangement: The Alta Energy Decision

The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy). Six of the nine justices held that the Canadian statutory general...more

Rivkin Radler LLP

Gifts, Sales and Effective Dates: The Race Against the Clock the Taxpayer Cannot See

Rivkin Radler LLP on

It was quite a week, wasn’t it?- Manchin- Senator Manchin continued to attract a lot of attention. To the dismay of his fellow Democrats, the West Virginian – who also chairs the Senate Energy and Natural Resources...more

Mintz - ML Strategies

House Democrats Weigh Major Tax Changes for Businesses, Funds, and Individuals

Mintz - ML Strategies on

In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more

Barnea Jaffa Lande & Co.

Israeli-UAE Tax Treaty – Client Update

On May 31, 2021, Israel and the United Arab Emirates signed a tax treaty. This is the first tax treaty between the states. It is expected to go into effect on January 1, 2022, after passing the necessary ratification...more

Bennett Jones LLP

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

Bennett Jones LLP on

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

Ballard Spahr LLP

IRS CI Highlights International Efforts to Tackle Cryptocurrency Abuse, Money Laundering and Tax Evasion

Ballard Spahr LLP on

ABA Tax Fraud Panel to Discuss IRS CI and Crypto Criminals - The Internal Revenue Service – Criminal Investigation (IRS CI) has made it clear that it is focusing on the abuse of digital currencies to further tax evasion,...more

Bennett Jones LLP

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

Bennett Jones LLP on

On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more

Bennett Jones LLP

New Ratifications of the OECD's Multilateral Instrument Put Canadian Resource Holding Structures at Risk

Bennett Jones LLP on

Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

Proskauer Rose LLP on

EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more

White & Case LLP

Belgian draft law ratifying the MLI: A new paradigm in international tax law

White & Case LLP on

On February 4th, 2019, the Belgian government released a draft law ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "Convention") and the...more

Proskauer Rose LLP

UK Tax Round Up - August 2017

Proskauer Rose LLP on

UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more

Proskauer Rose LLP

Tax Round Up - June 2017

Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Proskauer - Tax Talks

Proposed New UK Penalties Regime Precipitated by CRS

Proskauer - Tax Talks on

Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities...more

Dechert LLP

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

Dechert LLP on

India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more

Proskauer - Tax Talks

Tax Announcements in the UK’s Budget 2016

Proskauer - Tax Talks on

The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our...more

27 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide