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Unallowable purpose and utilising existing losses

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

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

California property tax and Proposition 19

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

Important considerations when receiving an inheritance

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

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

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

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

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.

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.

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

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.

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

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.

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

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.

Tax aside? Private investment fund side letters

Their length, complexity and volume has increased over the years

Works of art and the conditional exemption tax incentive scheme

Tax considerations usually come into play at this stage.

Singapore Budget 2024: Extension and Refinement of Singapore Fund Tax Incentive Schemes

The inclusion of offshore funds in the foreshadowed revisions to the economic criteria for qualifying funds is notable

Baker McKenzie Welcomes 30 Mentees to 2024 NBLSA Tax Mentor Program

This is the largest mentee cohort the Firm has hosted since launching the program in 2019.

Guidelines for the application of the 12% VAT rate on the hiring of pleasure boats

It is essential to clarify that not all items can be subject to the reduced VAT rate; rather, only supplies commonly offered during the course of hiring a pleasure boat may be eligible for the reduced rate.