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Private Equity International Tax Issues

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more

Hogan Lovells

All roads lead to Luxembourg – why the Grand Duchy matters to Asia Pacific private capital

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Luxembourg is the largest centre for funds in the world outside the United States (U.S.). The country offers much for Australian PE investors. We look at what makes it so attractive....more

Hogan Lovells

Changes under the Future Financing Act – Employee equity finally future-proof?

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With the recently published draft of a "Future Financing Act", the federal government has reacted to the criticism on the tax treatment of equity instruments granted to employees. From the perspective of young companies, the...more

Hogan Lovells

Änderungen durch das Zukunftsfinanzierungsgesetz – Mitarbeiterbeteiligung endlich zukunftsfest?

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Mit dem kürzlich veröffentlichten Entwurf eines „Zukunftsfinanzierungsgesetzes“ hat die Bundesregierung auf die Kritik zur steuerlichen Behandlung von Mitarbeiterbeteiligungen reagiert. Die vorgesehenen Änderungen sind aus...more

Bilzin Sumberg

Responsibly Funding Our Priorities – House Yields Decisive Reconciliation Action

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As you may be aware, the House Ways and Means Committee recently approved a multitrillion-dollar tax package (the “Proposal”) that has significant tax impact on both individuals and corporations. ...more

Jones Day

Dutch Limited Partnerships Attractive Alternative to Luxembourg and Irish Fund Structuring

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Proposed changes to Dutch tax law will make Dutch limited partnerships attractive private equity and venture capital fund and feeder fund alternatives to Irish and Luxembourg equivalents. A Dutch limited partnership...more

Proskauer Rose LLP

UK Tax Round Up - February 2021

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UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more

Proskauer Rose LLP

UK Tax Round Up - December 2020

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COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

Proskauer - Tax Talks

High Court decision highlights importance of ensuring claims notices include required information

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In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more

Proskauer Rose LLP

UK Tax Round Up - February 2020

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UK General Tax Developments - HMRC updates to the private sector IR35 rules - On 7 February 2020, HMRC confirmed that the new private sector IR35 rules will only apply to payments made for services provided on or...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

Proskauer Rose LLP

UK Tax Round Up - December 2019

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UK Case Developments - IR35 – no mutuality of obligation to create a contract of employment - RALC Consulting Ltd v HMRC has provided the First-tier Tribunal (FTT) with another opportunity to consider the application...more

Faegre Drinker Biddle & Reath LLP

Leveraged Acquisitions Roundtable

Drinker Biddle’s Corporate and Securities Group recently hosted its 13th annual roundtable discussion, which took place at Gulph Mills Golf Club in King of Prussia, Pennsylvania. This year’s event sported a new name—“The...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

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UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

Proskauer Rose LLP

UK Tax Round Up - September 2019

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Case Law Developments - Place of supply for VAT purposes - The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more

Proskauer Rose LLP

UK Tax Round Up - April 2019

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UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more

Holland & Knight LLP

Mexico Grants Tax Incentives on Capital Gains, Corporate Bond Interest

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A Presidential Decree by Mexico President Andrés Manuel López Obrador granting a new set of income tax incentives to capital gains and interests derived from corporate bonds (the Decree) became effective on Jan. 9, 2018. ...more

Bennett Jones LLP

Due North: U.S. Private Equity Sets Sights On Canada - Infographic

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The outlook for private equity investment in Canada is promising. The country has become an attractive destination for foreign investors, and the total value of PE deals continues to reach new heights. A strong Canadian...more

Bennett Jones LLP

Due North: U.S. Private Equity Sets Sights on Canada

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The outlook for private equity investment in Canada is promising. The country has become an attractive destination for foreign investors, and the total value of PE deals continues to reach new heights. A strong Canadian...more

Vedder Price

Tax Reform: Impact on Private Equity and M&A

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On December 22, 2017, new tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Act”) was signed into law. The Act represents a major overhaul of the U.S. federal tax system and includes many new provisions,...more

Latham & Watkins LLP

Globally Taxing Issues for Private Equity

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Tax has, in recent months, become a frontpage issue with reaction to businesses not “paying their fair share” sitting alongside pressure on government finances and an uncertain political environment. In our view, the...more

McDermott Will & Emery

Focus on Private Equity - July 2014

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In This Issue: - Latin American Private Equity on the Rise - Tax Considerations When Acquiring Non-U.S. Portfolio Companies—Mitigating Subpart F Inclusions - Private Equity Funds at Higher Risk of...more

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