Tag Archives: Taxation

ILN Today Post

Managing Partners Selected as 2018 South Florida Power Leaders

Shutts & Bowen is pleased to announce that partners Joseph M. Goldstein, Arthur J. Menor and Francis E. Rodriguez have been selected as South Florida Power Leaders by the South Florida Business Journal. This year’s list reflects a “dynamic regional marketplace” and highlights leaders from South Florida’s private, public and civic sectors who have steered their companies to prosperity and helped the region thrive.

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ILN Today Post

Beskatning af udbytte – Ejerforholdene er afgørende!

Maskeret udbytte kan ramme aktionærer hårdt, selv hvis de er blevet bedraget af deres partnere.

Denne klumme er den tredje klumme i en række klummer omkring mere eller mindre overraskende beskatningsformer. I denne klumme vil der blive sat fokus på udbyttebeskatning af kapitalejere (dvs. aktionærer og anpartshaveres beskatning af udbytte, der oppebæres fra deres selskab).

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ACCIV and AMIT twinning? Proposed ACCIV tax regime

The release of the proposed tax rules for the new corporate collective investment vehicle (CCIV) is a welcome development for fund managers considering the structuring options for future funds or future conversion of existing funds into CCIVs.

There is a certain familiarity with the proposed tax regime for CCIVs. Unsurprising, given the regime substantially imports and adopts the managed investment trust (MIT) and attribution MIT (AMIT) regimes.

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ILN Today Post

Major change to the taxation of commercial property

Radical changes to the taxation of UK real estate were announced in the autumn Budget.

Investment into UK real estate has long had a privileged status, especially for investors based overseas. But over the last few years those tax privileges have been whittled away.

Two years ago the UK extended Capital Gains Tax to individuals and closely held companies owning UK residential property. Last year the UK tax code was amended to make sure that profits from development of UK land were taxed wherever they arose. And in this year’s Budget the Government has announced that with effect from April 2019 offshore investors will pay Capital Gains Tax on their profits from UK commercial real estate.

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What does the Great Repeal Bill mean for direct taxation in the UK?

Neal Todd, a partner at Fladgate LLP, goes over what the Great Repeal Bill could mean for direct taxation, as the UK exits the EU

Whatever aspects of life the electorate thought they were bringing back under control by voting to leave the European Union in last year’s referendum, it is hard to believe that direct taxation was high amongst their list of priorities.

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Talking Tax – Issue 69

ATO guidance

Residency test for companies – central management and control

Australian business groups with overseas operations are reminded to take care following the outcome of the High Court decision in Bywater Investments Limited & Ors. v Commissioner of Taxation; Hua Wang Bank Berhad [2016] HCA 45, and the recent release of Draft Tax Ruling TR 2017/D2 by the Australian Taxation Office (ATO).

The draft ruling sets out the Commissioner of Taxation’s view on the application of the central management and control test for companies following the landmark High Court decision.

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ILN Today Post

Russell P. Hintze, Board Certified Tax Attorney, Joins Shutts & Bowen

MIAMI—Shutts & Bowen is pleased to announce that Russell P. Hintze has joined the firm’s  Orlando office as a partner in the Tax and International Law Practice Group.

Mr. Hintze is a board certified tax lawyer focusing his practice in the areas of joint ventures and transactional tax matters. He has extensive experience in general business tax planning, corporate tax, limited liability companies, partnerships, tax planning for real estate, and mergers and acquisitions.

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Will the new tax regime for the capital gains arising from sale of Russian property be actually postponed under the DTT with Cyprus?

On December 29, 2016 the Ministry of Finance of the Republic of Cyprus on its official website issued an announcement that an agreement has been reached between the Russian and Cypriot authorities for postponing the application of the Protocol of October 7, 2010 amending Article 13 of the Double Tax Treaty between the Government of the Russian Federation and the Government of the Republic of Cyprus “On Avoidance of Double Taxation with respect to taxes on income and capital” dated December 5, 1998 (hereinafter – Russia-Cyprus DTT)1. In the announcement, it is also indicated that an additional Protocol is being finalized, providing for the application of the revised provisions of Article 13 of the Russia-Cyprus DTT, until similar provisions are introduced in other bilateral agreements for the Avoidance of Double Taxation between the Russian Federation and other European countries.

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ILN Today Post

Dej-Udom & Associates Newsletter – March 2016

ASEAN Economic Community News

US-ASEAN Connect
The United States and the leaders of the 10 ASEAN member countries launched the US-ASEAN Connect, an economic cooperation initiative, during last month’s leadership summit in California. The initiative has four pillars. Business Connect to support increased commercial engagement between U.S. and ASEAN businesses in regionally important sectors. Energy Connect to assist in the development of power sectors using sustainable and innovative technologies. Innovation Connect to support Southeast Asia’s entrepreneurs through policy support, technical support, and knowledge exchange. Policy Connect to support ASEAN in creating a stable policy environment favorable to trade and investment. The US government also agreed to establish centers in Singapore, Jakarta, and Bangkok to support the initiative and coordinate US economic engagement in ASEAN.

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ILN Today Post

Amanda R. Anderson Rejoins Lewis Rice

Lewis Rice LLC is pleased to announce that Amanda R. Anderson has rejoined the St. Louis office in the Taxation Department. Mandy has experience in all aspects of tax planning for partnerships and LLCs, corporations, and real estate transactions. She counsels clients with issues concerning mergers and acquisitions, real estate projects, and complex partnership issues. Mandy also advises clients on a range of entity issues and assists with federal income tax treatment of pass-through entities.

In her corporate practice, Mandy represents corporations, nonprofits, financial institutions, and school districts in the areas of mergers and acquisitions, real estate, corporate finance, general corporate law, and corporate governance.

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