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Results: 1-10 of 16

Preview 2013 (UK law)

  • Herbert Smith Freehills LLP
  • -
  • European Union, United Kingdom
  • -
  • January 15 2013

2013 will herald some significant changes to the UK legal arena, notably in the corporate area in relation to executive remuneration and narrative

FATCA effective date is fast approaching

  • Clayton Utz
  • -
  • Australia, USA
  • -
  • September 3 2012

The Australian Government announced on 28 August that it is exploring the feasibility of an intergovernmental agreement (IGA) with the US to minimise the costs for Australian stakeholders of complying with Foreign Account Tax Compliance Act (FATCA

CFTC sues Royal Bank of Canada for years long wash sale scheme

  • Dorsey & Whitney LLP
  • -
  • Canada, USA
  • -
  • April 4 2012

The Commodity Futures Trading Commission filed an enforcement action against the Royal Bank of Canada alleging a years long, riskless wash sale scheme conducted by a small group of RBC personnel to generate certain lucrative Canadian tax benefits

Anschutz Company

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 13 2012

Just before New Year’s Eve 2011 the Tenth Circuit affirmed the Tax Court’s ruling against the taxpayer Anschutz Company in a case involving a variable prepaid forward contract

Financial services legislative and regulatory update - October 10, 2011

  • Mintz Levin Cohn Ferris Glovsky and Popeo PC
  • -
  • USA
  • -
  • October 10 2011

The theme of this past week is anger, primarily espoused by the Occupy Wall Street protests who continue to garner attention for their disenchantment with the financial services industry, corporate America and government

International regulatory update 19-23 September 2011

  • Clifford Chance LLP
  • -
  • European Union, France, Germany, Japan, Libya, Netherlands, Poland, United Kingdom
  • -
  • September 28 2011

The Comisión Nacional del Mercado de Valores (National Securities Market Commission) (CNMV) has published an updated set of FAQs in relation to its temporary measure on net short positions

Talk tax quarterly news

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 22 2011

Just as we were going to press bemoaning the impending January 1, 2013 effective date of the Foreign Account Tax Compliance Act, the Internal Revenue Service and Treasury Department announced an extension of the new provisions’ withholding and reporting requirements

Hedging for tax purposes - does the common law require an underlying transaction?

  • Gowling Lafleur Henderson LLP
  • -
  • Canada
  • -
  • June 22 2011

Canada Revenue Agency (“CRA”) recently released four internal technical interpretations (“TIs”) on the characterization of foreign exchange (“FX”) gains or losses from forward contracts used to hedge foreign investments

Payments under interest rate swap agreements do not constitute interest for purposes of withholding tax

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Singapore
  • -
  • February 11 2011

An interesting decision was given by the Singapore High Court in ACC v Comptroller of Income Tax 2010 SGHC 316 recently dealing with the question whether payments made under an interest rate swap agreement could constitute interest and thus be subject to withholding tax in terms of the relevant Treaty

Singapore High Court finds payments made under interest rate swap agreements for hedging purposes not a payment in connection with any loan or indebtedness and not subject to withholding tax

  • Allen & Gledhill LLP
  • -
  • Singapore
  • -
  • January 26 2011

In ACC v Comptroller of Income Tax 2010 SGHC 316, the Singapore High Court held that payments made by one counterparty to the other under interest rate swap agreements did not constitute "any other payment made in connection with a loan or indebtedness" within the meaning of section 12(a)(i) of the Income Tax Act and that, accordingly, such payments are not deemed to be derived from Singapore with the consequence that the requirement to withhold tax under the Income Tax Act did not apply to such payments

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