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1
UK Tax Round Up - May 2019
Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this month
UK
15 Jul 2019
2
Wealth Management Update - July 2019
The Supreme Court ruled unanimously on June 21, 2019, that a trust beneficiary's residence in a State, standing alone, is not sufficient for that State to impose income tax on that trust.
United States
12 Jul 2019
3
State Tax On Trust Income Based Solely On In-State Residence Of Beneficiaries Found Unconstitutional
On June 21, 2019, the United States Supreme Court decided North Carolina Dept. of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter, "Kaestner").
United States
11 Jul 2019
4
UK Tax Round Up - June 2019
In Development Securities plc and others v HMRC, the Upper Tribunal (UT) has overturned the prior discussion of the First-tier Tribunal (FTT) in favour of the taxpayer.
UK
10 Jul 2019
5
Upper Tribunal Rules In Favour Of Taxpayer In Tax Residence Case
As we reported in our August 2017 UK Tax Round-Up [https://www.proskauer.com/newsletter/uk-tax-round-up-august-2017], the UK's First Tier Tribunal
United States
2 Jul 2019
6
Final IRS Regulations Sync Section 956 With TCJA Participation Exemption – Limits "Deemed Dividends" For U.S. Corporate Shareholders Of CFCs
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.
United States
14 Jun 2019
7
Section 1446(f) Proposed Regulations: Key Guidance On Partnership Interest Transfers By Non-U.S. Persons
On May 13, 2019, the IRS and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests ...
United States
6 Jun 2019
8
Players, Staff And Draft Picks May Be Traded Tax-Free Under New Safe Harbor
On April 11, 2019, the Internal Revenue Service (the "IRS") issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts
United States
14 May 2019
9
UK Tax Round Up - April 2019
In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in a share sale is simply the difference between the amount paid...
UK
10 May 2019
10
Proposed FDII Regulations Under Section 250
On March 4, 2019, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") released proposed regulations (the "Proposed Regulations")
United States
7 May 2019
11
Parsonage Exclusion Found By Seventh Circuit To Be Constitutional
On March 15, 2019, the U.S. Court of Appeals for the Seventh Circuit held in Gaylor v. Mnuchin that the tax exemption for "ministers of the gospel" (defined below) under Section 107(2)
United States
17 Apr 2019
12
UK Tax Round Up - March 2019
At the end of February, the Court of Justice of the European Union (CJEU) issued two judgments addressing the circumstances ...
European Union
11 Apr 2019
13
EU Updates List Of Non-Cooperative Jurisdictions For Tax Purposes – Crown Dependencies Moved To White List
Following lengthy consideration since December 2017, the European Union, on 12 March, updated its blacklist of non-cooperative jurisdictions in tax matters.
European Union
3 Apr 2019
14
Five Excise Tax Tips For Tax-Exempt Employers
As we have previously discussed, the 2017 tax reform act created a new excise tax under section 4960 of the Internal Revenue Code that will affect many tax-exempt employers.
United States
21 Mar 2019
15
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
16
UK Tax Round Up – February 2019
The Finance Bill 2019 received Royal assent on 12 February 2019 becoming the Finance Act 2019. Among numerous other things,
UK
13 Mar 2019
17
Proposed Rental Business Safe Harbor Under Section 199A
On January 18, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury issued final regulations on the "pass through" deduction under section 199A[1] of the Internal Revenue Code (the "Code").
United States
13 Feb 2019
18
UK Tax Round Up - January 2019
Three significant changes have been made to the Finance Bill published last October which will be included in the Finance Act 2019 (expected to receive Royal Assent in early February).
UK
11 Feb 2019
19
Proposed Anti-Hybrid Regulations Under Sections 267A, 245A, And 1503(d)
On December 20, 2018, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") ...
United States
30 Jan 2019
20
Interim Guidance Released On Excise Tax On Executive Compensation Paid By Tax-Exempt Organizations
The Department of the Treasury and the Internal Revenue Service recently released Notice 2019-09 (the "Notice"), which provides interim guidance under Section 4960 of the Internal Revenue Code.
United States
21 Jan 2019
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