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Proskauer Rose LLP
A key initial decision for a manager launching a new hedge fund is to decide between...
Proskauer Rose LLP
Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments.
Alvarez & Marsal
In this article, we explore the landmark decision in Pepsi Inc v Commissioner of Taxation [2023] FCA 1490 and its implications for the characterisation of royalties for multinational enterprises.
Mayer Brown
In March 2024, the Internal Revenue Service ("IRS") released a new revision to Form W-9. Forms W-9 previously provided or collected do not expire nor need to be refreshed due...
Bennett Thrasher
The Federal Research and Development Credit, or R&D Tax Credit allows companies engaged in qualified R&D activity to claim a tax credit for their efforts.
Crowell & Moring LLP
On December 19, 2023, the bilateral income tax treaty between the United States and Chile (formally, the Convention between the Government of the United States of America and the Government...
Alvarez & Marsal
In today's competitive business environment, companies must continuously be seeking innovative strategies to drive growth, enhance profitability, create employment opportunities, and successfully...
Proskauer Rose LLP
Welcome to December's edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income...
Cadwalader, Wickersham & Taft LLP
YA Global Investments, LP ("YA Global"), a foreign investment fund that provided funding to portfolio companies in exchange for stock, convertible debentures, promissory notes and warrants...
Ogletree, Deakins, Nash, Smoak & Stewart
On November 9, 2023, Alabama Governor Kay Ivey signed into law a bill that beginning on January 1, 2024, will make compensation received by full-time hourly wage-paid employees...
This Client Alert is intended to remind you of certain year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the "Code"), with respect...
Mayer Brown
For years, the YA Global litigation has attracted the attention of many tax practitioners and private fund industry stakeholders.
Ruchelman PLLC
The comedian, Mel Brooks, once uttered a quip for the ages: "It's good to be king!" The thrust of the statement was that those in power can do what they want.
Katten Muchin Rosenman LLP
Given the breadth and depth of its economy and financial markets, the liquidity of its securities, commodity futures, swaps and options exchanges, and its robust legal and regulatory framework...
Kramer Levin Naftalis & Frankel LLP
On Dec. 19, 2023, Treasury announced the entry into force of the U.S.-Chile bilateral income tax treaty (the Tax Treaty). The Tax Treaty is the first new comprehensive...
Shearman & Sterling LLP
On December 19, 2023, the U.S. Treasury Department ("Treasury") announced the entry into force of the U.S.-Chile Income Tax Treaty (the "Treaty").
Ropes & Gray LLP
The UK's tax strategy stabilised in 2023 – at least in the near-term – following a very disruptive 2022. Two fiscal events saw comparatively uneventful policymaking generally welcomed by the business community.
Ruchelman PLLC
A robust and extensive income tax treaty network has worked to the advantage of U.S. corporations and individuals.
Ruchelman PLLC
If you are a tax professional, you know your client is in a pickle if a tax provision disallows a deduction and another provision subjects the corresponding income to U.S. tax.
Kramer Levin Naftalis & Frankel LLP
On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty)...
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