Articles: 1-10 of 193
Bluecrest - the Upper Tribunal considers the salaried member rules
United Kingdom - September 22 2023 The Upper Tribunal (UT) has upheld the decision of the First‑tier Tribunal (FTT) regarding the application of the UK’s salaried member rules (the…
Senate Finance Committee Requests Public Comments on Digital Asset Taxation
USA - August 30 2023 On July 11, 2023, the Senate Finance Committee released an open letter to the Digital Asset Community asking a variety of questions in connection…
New Bill Would Deny Section 892 Benefits To Certain Sovereign Wealth Funds
USA - August 1 2023 On July 26, 2023, Senate Finance Chairman Ron Wyden (D-OR) introduced the Ending Tax Breaks for Massive Sovereign Wealth Funds Act (the “bill”)…
Tax Court Provides Helpful Guidance on Requirements for Tax-Free Profits Interests
USA - May 26 2023 On May 3, 2023, the United States Tax Court held in ES NPA Holding, LLC v. Commissioner, T.C. Memo. 2023-55, that the taxpayer’s receipt of interests…
Proposed Regulations Issued for Repatriations of Intangible Property under Section 367(d)
USA - May 22 2023 On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would…
Recent Legislative Proposals and IRS Guidance on the Taxation of Digital Assets
USA - May 2 2023 This blog post summarizes recent federal bills that have been introduced (but not yet passed), proposals by the Biden Administration, and guidance…
Proskauer Tax Talks: Green Book 2024
USA - April 24 2023 On March 9, 2023, the Biden Administration released the Fiscal Year 2024 Budget, and the “General Explanations of the Administration’s Fiscal Year…
Upcoming changes to the company share options plan regime
United Kingdom - March 15 2023 Company share option plans (CSOP) and enterprise management incentives (EMI) are two statutory share option regimes that can be used to incentivise…
IRS and Treasury Provide Guidance on the Excise Tax on Repurchases of Corporate Stock under Section 4501
USA - February 1 2023 On December 27, 2022, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) released Notice 2023-2 (the…
New Proposed Regulations Would Impact the Determination of Domestically Controlled REIT and Structures for Sovereign Wealth Funds’ US Real Estate Investments
USA - January 13 2023 On December 28, 2022, the Internal Revenue Service (the “IRS”) and the Treasury Department released proposed regulations (the “Proposed Regulations”)…
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