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Dechert LLP

Labour Budget 2024: Reforms to the Taxation of Carried Interest

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The Chancellor of the Exchequer, Rachel Reeves MP, presented her first Budget to Parliament on 30 October 2024. In it, she announced both tax rate increases and also proposals which would fundamentally change the tax...more

White & Case LLP

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

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In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

Walkers

Guernsey announces further details of OECD Pillar Two implementation

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Following on from the Crown Dependencies re-affirming their commitment to implementing the Organisation for Economic Co-operation and Development’s Pillar Two framework for accounting periods commencing on or after 1 January...more

Walkers

Guernsey and Jersey re-affirm commitment to OECD Pillar Two implementation

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The Crown Dependencies have re-affirmed their commitment to international tax standards and the continued value of inter-island cooperation in areas of mutual interest in international tax policy. Ministers from...more

Mayer Brown

Brazilian Tax Reform: Complementary Bill of Law No. 68/2024

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On April 24, 2024, the Executive Branch introduced Complementary Bill of Law No. 68/2024 ("PLP 68" or the “Bill”), which creates the Tax and the Contribution on Goods and Services ("IBS" and "CBS") as well as the Selective...more

Blake, Cassels & Graydon LLP

Les rouages de la nouvelle taxe sur les services numériques au Canada

Le gouvernement du Canada a présenté la tant attendue Loi sur la taxe sur les services numériques (la « Loi ») au Parlement le 30 novembre 2023 dans le cadre du projet de loi C-59. Dans nos Bulletins Blakes antérieurs...more

Blake, Cassels & Graydon LLP

The Mechanics of Canada’s New Digital Services Tax

Canada’s long-anticipated Digital Services Tax Act (Act) was introduced into Parliament on November 30, 2023 as part of Bill C-59. While our previous Blakes Bulletin: 2023 August 4 Draft Legislation: Selected Tax Measures and...more

Mayer Brown

Tax Law Highlights | Brazilian Tax Reform And Expectations For Its Regulation

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The Brazilian Tax Reform on consumption was enacted through Complementary Amendment No. 132/2023, which unified the main taxes on the consumption of goods and services in the form of a Dual VAT and through the creation of a...more

Mayer Brown

Brazil Tax News: Laws, Provisional Measures, Normative Instructions, and Bill of Law Approved at End of December 2023

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Several new rules were approved on December 28, 2023, all extremely relevant to tax law. Our tax team summarizes some of the more relevant new rules...more

Stikeman Elliott LLP

Employee Ownership Trusts: Full Steam Ahead After Government’s Fall Economic Statement

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On November 21, 2023, the Government of Canada released its Fall Economic Statement. Among the measures included in the statement are improved tax incentives for Employee Ownership Trusts (“EOTs”)....more

Blake, Cassels & Graydon LLP

Propositions législatives du 4 août 2023 : Présentation de certaines mesures fiscales

Le 4 août 2023, le ministère des Finances (le « ministère ») a publié de multiples propositions législatives et notes explicatives connexes (les « propositions du 4 août »). Ces propositions du 4 août comprennent des...more

Blake, Cassels & Graydon LLP

2023 August 4 Draft Legislation: Selected Tax Measures

On August 4, 2023, the Department of Finance (Finance) released a significant package of draft legislative proposals and related explanatory notes (August 4 Proposals). The August 4 Proposals include updated legislative...more

Brownstein Hyatt Farber Schreck

Ways and Means Committee Republicans Release Pillar Two Remedies Proposal

House Ways and Means Committee Chairman Jason Smith (R-MO) and committee Republicans released legislation on May 25, 2023, in response to the Pillar Two global minimum tax negotiated by the Organisation for Economic...more

Littler

A Deep Dive into Recent Pension Tax Changes in the UK

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In March, the UK government announced changes to the tax regime surrounding pensions as part of the annual Budget. In this piece, we take a deep dive into what these changes are, who they affect, what employers should be...more

Morgan Lewis

Dividend Taxation in Kazakhstan: Additional Condition to Apply Double Tax Treaty

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Recent changes to the Kazakhstan Tax Code introduced an additional condition for applying a double tax treaty when paying dividends in Kazakhstan. To illustrate the current regime, consider the following scenario wherein...more

Akin Gump Strauss Hauer & Feld LLP

UK Spring Budget 2023: Points for Asset Managers

Introduction - On 15 March 2023, the UK government revealed the widely anticipated Spring Budget, which contained a number of measures that may be of interest to asset managers....more

A&O Shearman

OECD Pillars: Full steam ahead

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2023 is set to be a year of change for the global tax landscape. After many years of negotiation, development and consultation, implementation of the OECD’s Pillar One and Pillar Two reforms to international taxation is now...more

A&O Shearman

UK commits to global minimum tax rate

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The UK government has used the opportunity of its Autumn Statement 2022, delivered on 17 November, to confirm that the Finance Bill 2022 will include legislation introducing a 15% global minimum corporation tax rate, to have...more

Kramer Levin Naftalis & Frankel LLP

Proposed Legislation Would Impose New Corporate Minimum and Excise Taxes

On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 14, 2022

Kustoff Joins Ways and Means. Rep. David Kustoff (R-TN) has been selected to replace former Rep. Tom Reed (R-NY), who resigned from Congress earlier this year, on the House Ways and Means Committee. He will sit on the Worker...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the U.S. International Tax Rules

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Introduction and Summary - On March 28, 2022, the Biden Administration proposed changes to the U.S. international tax rules. In short, the Biden Administration proposed to: Enact a 15% minimum “undertaxed profits...more

Freeman Law

Tax Treaty-Based Return Reporting Disclosures

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A taxpayer taking a treaty-based return position is generally required to disclose that position, unless an exception applies. A treaty-based return position is a tax reporting position, maintaining that a U.S. tax treaty...more

Miller Nash LLP

Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies

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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more

McDermott Will & Emery

[Webinar] Tax in the City® - March 1st, 11:30 am - 1:00 pm PDT

The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies. Join us for our first Tax in the City® program of 2022, which will cover federal and...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

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On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

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