Tax

A discussion of the Foreign Account Tax Compliance Act (FATCA), its impact on loan agreements and links to recent large corporate and middle market deals summarized in What's Market with FATCA specific provisions from 2011, 2012 and 2013. This Note will be updated quarterly.

This Note addresses the application of US transfer pricing rules to specific cross-border transactions among related entities. It discusses the US transfer pricing rules for loans and guaranties, transfers of tangible and intangible property, provision of services and global trading operations.

This Note provides a general overview of US transfer pricing rules, and focuses on the relevance of US transfer pricing rules to cross-border transactions among related entities.

This Note provides an introduction to the purposes of and common provisions in US income tax treaties.

This Note discusses the US federal income tax consequences of owning common stock of a US corporate issuer.

An introduction to US corporate taxation, covering general concepts, entity classification, treatment of income and gains (including foreign profits) and the taxation of corporate transactions.This article is part of the PLC US Special Report, which was published to mark the launch of PLC's first US services.

Financial sponsors and other sellers are increasingly using tax receivable agreements to monetize tax attributes of corporations being brought to market in initial public offerings (IPOs).

An employee policy on reimbursement of travel and other business expenses incurred by employees in the ordinary course of company business. It addresses reimbursement for travel, lodging, meals, entertainment and other business expenses. It can be incorporated into an employee handbook or used as a stand-alone policy document. It is based on federal law. State or local law may impose additional or different requirements but this document will be useful and relevant to employers in every state. This Standard Document has integrated notes with important explanations and drafting tips.

This article examines the principal provisions of the US Foreign Account Tax Compliance Act (FATCA), and analyses how those provisions can best be implemented in Brazil, where there are numerous conflicting points of local law to take into consideration. This article is part of the PLC multi-jurisdictional guide to Tax on Transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

This Note discusses the US federal income tax rules that apply to publicly traded partnerships.

This article is part of the PLC multi-jurisdictional guide to Tax on Transactions. For a full list of contents visit www.practicallaw.com/taxontransactionshandbook. Dividend tax is frequently referred to the ECJ and various EU member states have had aspects of their domestic legislation struck down. The European Commission has taken legal action against a number of member states whose dividend rules do not comply with the EC Treaty (TFEU). This article examines the legal framework, inbound dividends, outbound dividends, whether double-tax treaties can cure discrimination, and EEA and third countries.

This Note provides an overview of the basic US federal income tax rules that apply to commercial real estate leases and sale leasebacks.

This Note provides an overview of common tax issues that arise for buyers and sellers in acquisitions of financially distressed targets.

PLC Tax subscribers have access to an analysis article on the Aaronson Report on the possible introduction of a UK general anti-abuse rule (GAAR). The article forms part of the newly updated edition of the PLC Cross-border Tax on Transactions multi-jurisdictional guide.

PLC Tax subscribers have access to the newly updated edition of the PLC Cross-border Tax on Transactions multi-jurisdictional guide. The guide deals with cross-border issues and answers key questions on the tax treatment of corporate transactions from practitioners in 25 jurisdictions and on the tax treatment of finance transactions from practitioners in 10 jurisdictions.

A Q&A guide to tax on corporate transactions in Romania. This Q&A provides a high level overview of tax in Romania and looks at key practical issues including, for example, the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. This Q&A is part of the PLC multi-jurisdictional guide to Singapore. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in Hong Kong. This Q&A provides a high level overview of tax in Hong Kong and looks at key practical issues including, for example, the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. This Q&A is part of the PLC multi-jurisdictional guide to tax. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in the UK (England and Wales). This Q&A provides a high level overview of tax in the UK (England and Wales) and looks at key practical issues including, for example, the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool. This Q&A is part of the PLC multi-jurisdictional guide to tax. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in the Russian Federation. This Q&A provides a high level overview of tax in the Russian Federation and looks at key practical issues including, for example, the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool. This Q&A is part of the PLC multi-jurisdictional guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in Japan. The Q&A gives a high level overview of tax in Japan and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in Ireland. The Q&A gives a high level overview of tax in Ireland and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on Corporate Transactions Q&A tool Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in Gibraltar. The Q&A gives a high level overview of tax in Gibraltar and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in France. This Q&A provides a high level overview of tax in France and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in Cyprus. The Q&A gives a high level overview of tax in Cyprus and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on corporate transactions in Canada. This Q&A gives a high level overview of tax in Canada and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.  

A Q&A guide to tax on corporate transactions in Australia. The Q&A gives a high level overview of tax in Australia and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency. To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on finance transactions in the UK (England and Wales. This Q&A provides a high level overview of finance tax in the UK (England and Wales) and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. To compare answers across multiple jurisdictions, visit the Tax on corporate lending and bond issues Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on finance transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on finance transactions in South Africa. This Q&A provides a high level overview of finance tax in South Africa and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. To compare answers across multiple jurisdictions, visit the Tax on corporate lending and bond issues Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on finance transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on finance transactions in Mexico. This Q&A provides a high level overview of finance tax in Mexico and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. To compare answers across multiple jurisdictions, visit the Tax on corporate lending and bond issues Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on finance transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on finance transactions in Italy. This Q&A provides a high level overview of finance tax in Italy and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. To compare answers across multiple jurisdictions, visit the Tax on corporate lending and bond issues Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on finance transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on finance transactions in Hong Kong. This Q&A provides a high level overview of finance tax in Hong Kong and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. This Q&A is part of the PLC multi-jurisdictional guide to tax. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on finance transactions in France. This Q&A provides a high level overview of finance tax in France and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. To compare answers across multiple jurisdictions, visit the Tax on corporate lending and bond issues Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on finance transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on finance transactions in Canada. This Q&A provides a high level overview of finance tax in Canada and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. To compare answers across multiple jurisdictions, visit the Tax on corporate lending and bond issues Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on finance transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

A Q&A guide to tax on finance transactions in Argentina. This Q&A provides a high level overview of finance tax in Argentina and focuses on corporate lending and borrowing (including withholding tax requirements), bond issues, plant and machinery leasing, taxation of the borrower and lender when restructuring debt, and securitisations. To compare answers across multiple jurisdictions, visit the Tax on corporate lending and bond issues Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to tax on finance transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

An update on IRS guidance providing a continued suspension or waiver of FBAR filing requirements for certain persons.

The table summarises key succession regime provisions in the jurisdictions covered in the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg

This Note provides a brief overview of the different types of equity compensation available to employers. It then provides a more detailed discussion of stock options granted by public company employers to employees, specifically addressing tax, regulatory and other legal considerations.

This article considers the social security issues, in particular dual taxation and gaps in benefits protection, that arise when US employees are seconded abroad, and the availability of social security treaties to ensure that coverage, benefits and taxation remain as seamless as possible.

This Note focuses on the US tax issues that arise when a corporate borrower grants security to a lender in a secured financing transaction.

A Q&A guide to sales and use tax law in Washington. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns. Answers to questions can be compared across a number of jurisdictions (see Sales and Use Taxes: State Q&A Tool).

A Q&A guide to sales and use tax law in Texas. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns. Answers to questions can be compared across a number of jurisdictions (see Sales and Use Taxes: State Q&A Tool).

A Q&A guide to sales and use tax law in Ohio. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns. Answers to questions can be compared across a number of jurisdictions (see Sales and Use Taxes: State Q&A Tool).

A Q&A guide to sales and use tax in New Jersey. This Q&A addresses key areas of sales and use tax such as tax scope, multi-state transactions and collecting taxes and filing returns. Answers to questions can be compared across a number of jurisdictions (see Sales and Use Taxes: State Q&A Tool).

A Q&A guide to sales and use tax law in Minnesota. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns.

A Q&A guide to sales and use tax law in Massachusetts. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns. Answers to questions can be compared across a number of jurisdictions (see Sales and Use Taxes: State Q&A Tool).

A Q&A guide to sales and use tax law in Indiana. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns. Answers to questions can be compared across a number of jurisdictions (see Sales and Use Taxes: State Q&A Tool).

A Q&A guide to sales and use tax law in Georgia. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns. Answers to questions can be compared across a number of jurisdictions (see Sales and Use Taxes: State Q&A Tool).

A Q&A guide to sales and use tax law in Connecticut. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns. Answers to questions can be compared across a number of jurisdictions (see Sales and Use Taxes: State Q&A Tool).

A Q&A guide to sales and use tax law in California. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns.

This tool enables subscribers to search and compare PLC's Sales and Use Taxes Q&A resources. Questions and answers cover key areas of state sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filing returns. Simply select the questions and the jurisdictions that you are interested in and click the "Submit" button.

This Note discusses the extent to which an issuer recognizes cancellation of indebtedness income (CODI) in connection with a restructuring of outstanding debt securities.

Switzerland has long been a destination for wealthy individuals and families. This article examines features of Switzerland that are relevant for individuals and families including the recognition of trusts in Switzerland, the taxation of trusts, immigration to and residence in Switzerland and issues arising on immigration. This article is part of the PLC Private Client multi-jurisdictional guide. For a full list of jurisdictional Private Client Q&As visit www.practicallaw.com/privateclient-mjg

This Checklist identifies potential pitfalls that may cause a real estate investment trust (REIT) to lose its REIT status or be subject to penalty taxes and sets out ways to avoid or fix these problems. For more information about REITs, see Practice Note, REITs: Overview.

This chapter considers the tax issues that can arise when structuring cross-border private equity investments, with examples from the EU and the US.

A Q&A guide to private client law in Turkey. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private Client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in The Netherlands. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. This Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in Switzerland. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in South Korea. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in the Russian Federation. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in Mexico. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in Jersey. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in Italy. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. This Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in the Isle of Man. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in India. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in Guernsey. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. This Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg

A Q&A guide to private client law in France. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. This Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg 

A Q&A guide to private client law in China. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in Canada. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

A Q&A guide to private client law in Brazil. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. This Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg. 

A Q&A guide to private client law in Belgium. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; familial relationships; minority and capacity, and proposals for reform. To compare answers across multiple jurisdictions, visit the Private client Country Q&A tool. The Q&A is part of the PLC multi-jurisdictional guide to private client law. For a full list of jurisdictional Q&As visit www.practicallaw.com/privateclient-mjg.

An update on the Worker, Homeownership, and Business Act of 2009, which extends the net operating loss carryback period for losses realized in 2008 and 2009 from two years to five years.

A plan of liquidation and dissolution to be used for the dissolution of a Delaware corporation wholly owned by a US parent corporation. This Standard Document has integrated notes with important explanations.

This Note discusses the definition of a passive foreign investment company (PFIC), the US federal income tax consequences to a US investor in a PFIC and the disclosure obligations for PFICs.

This Article discusses the US reporting rules for US taxpayers with foreign accounts and assets (including FBAR and FATCA), the civil penalties for non-compliance with the US reporting rules, current US enforcement initiatives aimed at discovering US taxpayers with undeclared foreign accounts or assets, and the options for US taxpayers to address prior non-compliance with the US reporting rules.

Under changes made by the Hiring Incentives to Restore Employment Act enacted in 2010, US issuers are effectively precluded from issuing debt in bearer form for US tax purposes after March 18, 2012. This Note describes the US tax sanctions that apply to issuers and holders of bearer debt, and explains the features that distinguish bearer debt from registered debt for US tax purposes.

The Treasury Department published a model intergovernmental agreement to implement FATCA in consultation with France, Germany, Italy, Spain and the UK.

The Treasury Department announced a new intergovernmental framework to implement FATCA in joint statements with Japan and Switzerland.

This Note discusses the US federal income and withholding tax rules that potentially apply to payments made by a US corporate borrower to a foreign corporate lender under a loan agreement. 

This Note summarizes some key limitations on interest deductibility imposed on a US corporate issuer.

This Note provides an overview of the key US tax considerations when structuring a US-based joint venture.

An update on the publication of the 2010 Short Form HIRE Act Protocol by ISDA, superseding its August 23, 2010 HIRE Act Protocol.

An update on the IRS's revision of Notice 2011-53 to include withholdable payments to non-financial foreign entites in the phased implementation schedule for withholding under the Foreign Account Tax Compliance Act (FATCA) enacted as part of the Hiring Incentives to Restore Employment Act of 2010.

An update on an IRS proposal that would require annual reporting of uncertain tax positions by certain business taxpayers on their tax returns.

An update on recently issued temporary and proposed regulations addressing the treatment of dividend equivalent payments.

The IRS issued proposed regulations addressing withholding and information reporting requirements under the Foreign Account Tax Compliance Act (FATCA).

The Internal Revenue Service (IRS) issued Revenue Procedure 2012-29, effective June 25, 2012, which provides sample language that taxpayers may use to make an election under Section 83(b) of the Internal Revenue Code (IRC) and examples of the income tax consequences of making a Section 83(b) election in various situations.

An update on the IRS's issuance of guidance providing for the phased implementation of withholding and certain reporting provisions of the Foreign Account Tax Compliance Act (FATCA) enacted as part of the Hiring Incentives to Restore Employment Act of 2010.

The IRS and Treasury Department issued final regulations on IRC Section 336(e) deemed asset sale elections.

The IRS released an announcement that delays certain deadlines under the Foreign Account Tax Compliance Act (FATCA) and provides additional guidance on grandfathered obligations.

This Note describes the basic aspects of the FIRPTA rules, including the types of property that qualify as US real property interests, the types of transactions subject to the FIRPTA rules and the withholding obligations applicable to dispositions of US real property interests by foreign persons.

Real Estate Investment Trusts play an increasingly important role in the world's capital markets. This article explains the reasons for this, the leading jurisdictions in which REITs are available and the main structures used.

This Note provides an overview of the significant US federal income tax consequences of corporate group restructuring transactions involving an LLC or partnership.

This Article provides an overview of the Foreign Account Tax Compliance Act's (FATCA's) impact on foreign funds and other foreign investment entities, in light of proposed regulations released in February 2012 by the IRS and Treasury Department.

An update on the House-passed jobs bill that includes new tax provisions to curb offshore tax evasion.

This Note provides an overview of the key US federal income tax issues for lawyers drafting guaranties and highlights some tax planning opportunities.

France is in the process of changing its tax landscape and now faces the tax reforms promised by President Hollande in his 2012 presidential election campaign. There is an increasing atmosphere of tax insecurity and on 28 September 2012 the new draft of the 2013 Finance Bill was released to practitioners and tax payers. The Finance Bill was finally adopted on 20 December 2012. It gave rise to a decision of the Constitutional Council which struck down numerous of its provisions including the 75% millionaire tax. The third amended Finance Bill for 2012 was adopted on 19 December 2012 and was also reviewed by the CC. While seeking to reduce the state deficit to 3% (the level required for Eurozone members), the Government must find approximately EUR30 billion of savings or additional income. Two thirds of this targeted amount will come from tax increases, of which EUR10 billion will be aimed at individual taxpayers (according to the Government, more specifically the wealthiest of those). Only a third of this amount will be derived from spending cuts. At the time of writing, reactions to the decisions of the CC remain to be proposed by the government and voted for by Parliament. Against this background, this article describes the main tax changes from 2012 and methods on how to prepare and respond to the tax increases. This article is is part of the PLC Private Client multi-jurisdictional guide. For a full list of jurisdictional Private Client Q&As visit www.practicalla

This Note discusses the US federal income tax consequences of owning common stock or American Depositary Shares (ADSs) of a foreign corporate issuer.

On January 2, 2013, President Obama signed the American Taxpayer Relief Act of 2012, which reinstates the top individual income tax bracket of 39.6% for higher income individuals, permanently extends lower rates for individuals with incomes below certain thresholds and extends a number of individual and business tax provisions.

The IRS issued final regulations on the definition of "publicly traded" debt which significantly expand the definition and make several changes to the proposed regulations issued in January 2011.

An update on final regulations issued by Financial Crimes Enforcement Network (FinCEN) on the Report of Foreign Bank and Financial Accounts (FBAR) requirements for US persons.

Financial Crimes Enforcement Network (FinCEN) further extends the deadline to file a Report of Foreign Bank and Financial Account (FBAR) by one year to June 30, 2013 for filing individuals that were previously extended in FinCEN Notices 2011-1 and 2011-2.

An update on the extension of the Report of Foreign Bank and Financial Accounts (FBAR) filing deadline for 2009 and previous calendar years for certain individuals with signature authority over foreign financial accounts.

An assessment of the international implications of the US Foreign Account Tax Compliance Act.

This Checklist provides timeline of important dates related to the Foreign Account Tax Compliance Act (FATCA) withholding tax which is generally phased in between 2014 and 2017.

This Checklist provides an overview of Foreign Account Tax Compliance Act (FATCA) timeline for the due diligence and reporting requirements that are generally phased in between 2013 and 2018.

This Article discusses the Foreign Account Tax Compliance Act (FATCA) provisions included in the Hiring Incentives to Restore Employment (HIRE) Act to target offshore tax evasion.

An expert Q&A with Bryan Skarlatos of Kostelanetz & Fink, LLP on the work product doctrine and the impact of the Textron decision.

An expert Q&A with Howard Cubell of Goodwin Procter LLP on the tax incentives relating to investment in qualified small business stock provided under the Small Business Jobs and Credit Act of 2010 and the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.

An expert Q&A with Kim Blanchard of Weil, Gotshal & Manges LLP and Andrew Solomon of Sullivan & Cromwell LLP on the Foreign Account Tax Compliance Act (FATCA).

This Article explains the steps an employer can take by the end of 2009 to correct or mitigate failures to comply with IRC Section 409A relating to deferred compensation plans and arrangements.

An update on the IRS release of a draft schedule and accompanying instructions for its proposal to require annual reporting of uncertain tax positions.

A checklist that summarizes the factors that influence whether a particular security is classified as debt or equity for US federal income tax purposes (for a more detailed discussion on this topic, see Practice Note, Debt v. Equity: US Tax Classification of Securities).

This chapter considers many of the technical aspects involved in structuring a joint venture between parties based in different countries. It focuses on the creation of joint ventures formed to carry on business independent of the joint venture parties. This article is part of the PLC multi-jurisdictional guide to Tax on Transactions. For a full list of contents visit www.practicallaw.com/taxontransactions-mjg.

This note details the UK corporate residence rules and explains how you can decide whether a company is resident in the UK for UK tax purposes. It also examines how you can decide whether a non-UK resident company has a UK permanent establishment and how UK permanent establishments are taxed under UK law. In addition, this note describes how the right to tax a company's profits may be divided under a double tax treaty if a company is resident in two territories or is resident in one territory but has a permanent establishment in another.

An update on an IRS announcement that extended the comment period for its proposal to require annual reporting of uncertain tax positions by certain business taxpayers on their tax returns. 

Chinese tax authorities have significantly increased their scrutiny of transactions conducted by non-resident enterprises, resulting in an increase in the tax revenues collected from non-residents. There has also been greater scrutiny of non-resident enterprises, ranging from foreign contractors and service providers, to financial investors. This article reviews the following in relation to the taxation of non-residents on their offshore transactions: History. Legislation. Latest cases. This article is part of the PLC multi-jurisdictional guide to Tax on Transactions. For a full list of contents visit www.practicallaw.com/taxontransactions-mjg.

This Chart provides a summary of the jurisdictions that have initialed or signed a model intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA)

This Note compares the US federal income tax consequences for buyers, sellers and targets in taxable and tax-free acquisitions of C-corporations versus S-corporations.