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Tax Liability Capital Markets

Conyers

Bermuda Corporate Income Tax and the Shipping Income Exclusion

Conyers on

In a landmark move on 27 December 2023 the Bermuda Government took a significant step by adopting the Corporate Income Tax Act 2023 (the “CIT Act”), a pivotal piece of legislation that promises to reshape the island’s...more

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

Stikeman Elliott LLP

Canada’s Proposed Share Buyback Tax

Stikeman Elliott LLP on

On August 4, 2023, the Department of Finance released a revised version of its proposed 2% equity buyback tax (“Buyback Tax”) that will apply to relevant transactions that occur on or after January 1, 2024....more

Woodruff Sawyer

1% Excise Tax, SPACs, and Independent Director Personal Liability: The Rock and the Hard Place

Woodruff Sawyer on

Being stuck between the choice of either disappointing investors or facing potential personal liability is the very definition of being caught between a rock and a hard place. Tax liability insurance can take you to a more...more

Hogan Lovells

Real estate securitisations: guidance by Italian tax authorities on the applicable tax treatment

Hogan Lovells on

With ruling No. 132 of 2 March 2021 (the “Ruling”), the Italian Tax Authorities (“ITA”) provided clarifications on the tax regime applicable to real estate special purpose companies (the “RE SPVs”) carrying out securitisation...more

WilmerHale

German Cum/Ex-Trades: Enhanced Risks and Industry-Wide Challenges

WilmerHale on

The German and international financial industries and their advisors have come under new pressure to investigate so-called 'cum/ex' trades conducted between 2000 and 2012. For many years, tax authorities and criminal...more

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