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Tax Talks Blog

Articles: 1-10 of 160

COVID-19: OECD updates its guidance on residence and permanent establishments

OECD, United Kingdom, USA - February 5 2021 From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and…

Regulations on Executive Compensation Excise Tax (Section 4960) for Tax-Exempt Employer and Their Affiliates Finalized

USA - February 2 2021 Employers that are tax-exempt or have tax-exempt affiliates (for example, a foundation) should pay close attention to a 21% Excise tax under Section…

Section 1061 Final Regulations on the Taxation of Carried Interest

USA - January 14 2021 On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations[1]…

Tax Proposals of President-Elect Biden and Other Prominent Democrats

USA - January 13 2021 This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats. Biden’s Proposals Individuals Increased…

Narrowing of UK intermediaries’ DAC 6 reporting requirements

European Union, OECD, United Kingdom - January 5 2021 On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported…

Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisions

USA - December 29 2020 On December 27, 2020, President Trump signed into law the Consolidated Appropriations Act, 2021 (the “Act”). The Act enhances and expands certain…

Court of Appeal decides that Jersey companies were UK tax resident

United Kingdom - December 23 2020 In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the…

Extension of FBAR Filing Deadline for Certain Filers

USA - December 23 2020 On December 9, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2020-1, extending the filing deadline for the Report of…

IRS issues new FAQs on the interaction between the employee retention tax credit and PPP loans in M&A transactions

USA - December 7 2020 On November 17, 2020, the U.S. Internal Revenue Service (“IRS”) posted new FAQs providing that an acquisition of the stock or assets of a company…

New OTS report recommends changes to UK’s capital gains tax regime

United Kingdom - November 13 2020 The Office of Tax Simplification (OTS) has published its first report following its review of certain aspects of the UK’s capital gains tax regime…