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Tax Liability Anti-Avoidance

Cadwalader, Wickersham & Taft LLP

The UK's Spring Budget 2024 and Its Impact on Real Estate

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

Bennett Jones LLP

Income Tax Update from the Supreme Court of Canada: The GAAR Does Not Apply to Treaty Shopping

Bennett Jones LLP on

The Duke of Westminster Principle Still Lives On for Tax Planning - On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC...more

Proskauer - Tax Talks

Extended tax liabilities for directors in insolvencies linked to tax avoidance

Proskauer - Tax Talks on

Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise...more

Fenwick & West LLP

IRS Notice 2018-26: Important New Guidance on the Mandatory Repatriation Tax

Fenwick & West LLP on

This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under § 965. Most importantly, the Notice sets forth extensive anti-avoidance rules in respect of...more

Latham & Watkins LLP

Tax-efficient Pension Savings in the UK: Government Applies Further Restrictions

Latham & Watkins LLP on

Employers may want to adjust compensation packages, and high-earners may want to revise their retirement savings strategies. In recent years, the UK government has reduced the lifetime and annual thresholds up to which...more

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