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Carried Interests in the Crosshairs (Again)

USA - February 25 2021 Democrats have proposed a bill to tax carried interests at ordinary income rates. Under current law, fund managers generally recognize income or gain…

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

UK Asset Holding Companies: What Does the Future Hold?

European Union, United Kingdom - February 25 2021 The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021…

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

Democrats Propose Mark-to-Market Tax and Increased Audits on High-Net-Worth Individuals

USA - February 25 2021 Democrats at both the federal and state levels are proposing a “mark-to-market” tax and legislation that would mandate more audits on high-income…

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

A Peek Behind the Curtain: IRS Musings on Spinoff Ruling Procedures

USA - January 26 2021 Speaking at several tax conferences this month, several senior IRS officials, including the Associate Chief Counsel, Corporate, discussed the nuances…

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

HMRC Announces Unexpected Changes to DAC 6

European Union, United Kingdom - January 26 2021 On 31 December 2020, the UK government published legislation that significantly restricts the scope in the United Kingdom of DAC 6, the mandatory…

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