Press Room: US Tax

Hybrid Mismatch Rules: Heads I lose, tails you win

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LLC’s Again – Here But Not There

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US Gift and Estate Tax update

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4 Friday, 2020

Private Client Case Review: Henkes v HMRC [2020] UKFTT 159 (TC)

Head of International Tax, Miles Dean, and National Technical Director, Andrew Parkes examine the issue highlighted in Henkes v HMRC and what this means for residents of the UK who have not yet become deemed domiciled.

2 Wednesday, 2020

The UK: Blackrock Holdco 5 LLC v HMRC: Unallowable Purpose and Transfer Pricing

Head of International Tax, Miles Dean, and Partner, Zoe Wyatt consider the case of Blackrock and its far-reaching impact on corporate transactions and the concept of unallowable purposes.

10 Tuesday, 2020

The UK: VAT on UK e-commerce imports post-Brexit

Sarah Shears, Head of VAT Group, provides an overview of VAT and e-commerce in light of the end of the Brexit transition approaching.

2 Monday, 2020

The US: Biden vs. Trump: How would a change in the Oval Office impact my tax affairs?

Julian Nelberg and Luke Jenkinson discuss how the recent election result in the US will impact individuals’ tax affairs.

22 Thursday, 2020

2020 Presidential Candidates’ Tax Proposals

2020 Presidential Candidates’ Tax Proposals.

13 Tuesday, 2020

US/UK: No one expects the hybrid mismatch rules

Andrew Parkes, National Technical Director, discusses how a minority equity investment by a US entity into a UK one, followed by an arm’s length loan, was not within the hybrid mismatch rules.

12 Monday, 2020

A discussion of VAT in the light of Brexit

Sarah Shears, Head of VAT Group at Andersen in the UK and Benno Tamminga, Managing Director in the US National Tax Practice with Andersen and the firm’s Global VAT leader, discuss the impact of Brexit on both the UK and the US in the EACC’s ‘Brexit Musings’ podcast.

28 Friday, 2020

California Dreaming (or Nightmare?)

It is no secret that California tax rates can be brutal, with the top rate reaching 13.3% on all income (including capital gains), so it is important for individuals to understand the scenarios in which they will become liable to California taxes, and how not to get caught out and inadvertently subject to tax.

18 Tuesday, 2020

Treasury and IRS release long-awaited guidance on carried interest taxation

On July 31, 2020, the Treasury and IRS released proposed regulations regarding Sec. 1061’s carried interest rule, targeting incentive allocations made to fund managers.

7 Friday, 2020

IRS issues guidance on GILTI high-tax exclusion

The Treasury and IRS have issued final regulations allowing taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their global intangible low-taxed income (GILTI) computation on an elective basis.

19 Friday, 2020

IRS announces plan to increase audits of wealthy individuals

The IRS is getting ready to examine hundreds of high net worth individual tax returns, as soon as the current moratorium on investigations expires on 15 July.

14 Sunday, 2020

Pre-move planning for individuals considering moving to the UK

Individuals moving to the UK should have a basic understanding of the UK tax system before they move, and consider pre-arrival planning to optimise their tax and avoid adverse consequences. The issues are especially important for Americans, who remain subject to US taxes and are therefore at risk of double taxation.

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