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Searching Content indexed under Tax Authorities by Proskauer Rose LLP ordered by Published Date Descending.
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Date
1
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
2
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
3
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
4
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
5
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
6
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
7
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
8
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
9
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
10
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
11
IRS Releases Interim Guidance On New Excise Tax On Executive Compensation Paid By Tax-Exempt Organizations
On December 31, 2018, the Department of the Treasury ("Treasury") and the Internal Revenue Service (the "IRS") released Notice 2019-09 (the "Notice"),
United States
18 Jan 2019
12
Tax Reform: UBTI Guidance On Qualified Transportation Fringe Benefits
From Proskauer's Not For Profit / Exempt Organization Blog, a discussion of recent IRS guidance and New York State legislative relief on Internal Revenue Code 512(a)(7)
United States
28 Dec 2018
13
Inclusion Of Qualified Transportation Fringe Benefits In UBTI: Guidance, Relief, And Rumors Of Possible Repeal
December 10, 2018 saw significant activity with respect to Section 512(a)(7) of the Internal Revenue Code (the "Code"), which requires tax-exempt employers ...
United States
28 Dec 2018
14
[Podcast]: Texas Judge Declares Affordable Care Act Unconstitutional
Hello and welcome to the Proskauer Benefits Brief legal insights on Employee Benefits and Executive Compensation.
United States
28 Dec 2018
15
FATCA: Significant Relief In New Proposed Regulations
On December 13, 2018, the Internal Revenue Service (the "IRS") and the U.S. Department of the Treasury (the "Treasury") issued proposed regulations
United States
21 Dec 2018
16
UK Tax Round Up - November 2018
The Finance (No 3) Bill 2018-19 (which will become the Finance Act 2019) was published on 7 November and includes legislation to enact the changes highlighted in our UK Budget blog post (UK Budget Blog).
Worldwide
30 Nov 2018
17
Newly Proposed US Tax Regulations Open Possibility Of Full Credit Support From Foreign Subsidiaries
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code.
United States
21 Nov 2018
18
Proskauer's 23rd Annual Trick Or Treat Seminar
Amanda Nussbaum welcomed everyone and briefly discussed the five major trends impacting tax-exempt organizations today, including the general impact of the Tax Cuts and Jobs Act (the "Act")...
United States
13 Nov 2018
19
Wealth Management Update - November 2018
These same rates are used in connection with sales to defective grantor trusts.
United States
9 Nov 2018
20
UK Tax Round Up: October 2018
The Autumn Budget will be presented later today and the Finance Bill 2019 will be published on 7 November.
UK
1 Nov 2018
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