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Tax

05/28/2024

Irish employers should review worker taxation classifications

This will be particularly relevant for businesses in certain sectors where Irish Revenue is likely to closely scrutinise the relationships with workers going forward.

05/24/2024

Get up to speed with ESOP changes for 2024 in Ireland

This briefing summarises some of the main unapproved share option schemes available to companies in Ireland.

05/17/2024

HMRC ‘dual role’ agents guidance of limited help to football clubs

Robotham was commenting after HMRC issued promotional material titled ‘Help with football agents' fees and dual representation contracts

05/14/2024

Unallowable purpose and utilising existing losses

Arrangements entered into to enable a group to utilise trapped losses more quickly had an unallowable purpose.

05/10/2024

IRS Issues New Ruling Policy on Spin-Off Transactions

New IRS Revenue Procedure Changes Ruling Practice for Retained Stock and Securities, Tax-Free Stock-for-Debt Exchanges and Debt Securities-for-Debt Exchanges

04/26/2024

California property tax and Proposition 19

The $1 million non-principal residence exclusion would be eliminated entirely.

04/26/2024

Important considerations when receiving an inheritance

Governing agreements often include restrictions on the rights of members to withdraw their interests

04/10/2024

Foreign dividends reform ‘a boost Ireland’s holding company credentials’

The proposal is to apply the exemption to “foreign dividends and other types of distributions that represent income

04/08/2024

VAT anti-abuse and domestic presumptions

Rebuttable presumptions based on the volume of turnover were an inappropriate and illegal basis for applying the abuse of law principle

04/04/2024

Allen & Overy’s Scott Cockerham on tax insurance in green energy credit deals

Allen & Overy’s Scott Cockerham on tax insurance in green energy credit deals

03/26/2024

NHS parking charges should be free of VAT, Court of Appeal rules

Having concluded on this point, the Court of Appeal considered whether non-taxation of NHS parking would create a distortion of competition.

03/25/2024

Irish tax treatment of some intra-group payments to change from 1 April

The change is given legal effect by the Finance (No. 2) Act 2023 and was trailed in a feedback statement issued by the Irish Department of Finance in July last year.

03/21/2024

Don't let your trust fall short: how tax season can reveal funding gaps

Another way to confirm your trust funding is to double-check the property tax bills for your real property

03/15/2024

OECD approach to ‘Amount B’ a milestone but global tax challenges remain

Tax rules provide that transactions between connected parties should be taxed as if they were on arm's length terms.

03/12/2024

Termination triggering discrimination claims: taxation

The question whether a payment is received in consequence of or otherwise in connection with termination of employment is to be construed widely

03/11/2024

UK taxpayers: time to disclose income and gains on cryptoassets

The key benefits of making an unprompted disclosure include reduced penalties and the waiving of late payment interest charges.

03/06/2024

HK Budget 2024-25: A Closer Look at the Tax Reforms

According to the government, this change will primarily affect some of the city's wealthiest individuals, impacting around 12,000 taxpayers

02/28/2024

Whenever, Wherever: lessons from Shakira's tax fraud case

This will result in a requirement to file tax returns and potentially pay tax in multiple jurisdictions.

02/27/2024

Tax aside? Private investment fund side letters

Their length, complexity and volume has increased over the years

02/23/2024

Works of art and the conditional exemption tax incentive scheme

Tax considerations usually come into play at this stage.

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Interim guidance following the Supreme Court's decision on the meaning of 'sex' in the UK Equality Act

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