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A New Approach to VAT Recovery

United Kingdom - January 22 2020 One of the more complicated issues in the world of VAT is the question of the entitlement to VAT recovery of certain holding companies and entities...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Adam Blakemore.

IRS Issues Final Opportunity Zone Regulations

USA - January 22 2020 I. Introduction On December 19, 2019, the IRS and Treasury issued final regulations on the Opportunity Zone program. The Opportunity Zone program is...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Adam Blakemore.

IRS Extends Delta-One Test for Withholding on Dividend Equivalents

USA - January 22 2020 On December 16, the IRS issued Notice 2020-2, which extends the phase-in of withholding under section 871(m). This is the latest in a series of such...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Adam Blakemore.

IRS Adds Transition Relief for Proposed NOL Limitation Rules on Built-in Gains and Losses

USA - January 22 2020 Finally responding to broad criticism, the IRS has updated its section 382 proposed regulations to provide transition relief, delaying the...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Adam Blakemore.

Taxpayer Expectations: Legitimate or Not?

United Kingdom - December 11 2019 The Court of Appeal in The Queen (on the application of Aozora GMAC Investment Limited) v HMRC 2019 EWCA Civ 1643 (Aozora) recently upheld the...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Adam Blakemore.