Tax information exchange and FATCA

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Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov

Most recent Tax information exchange and FATCA content

Practice notes
FORTHCOMING CHANGE: As described in this Practice Note, the scope of the UK’s disclosable arrangements rules was significantly reduced with effect...
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12th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 9th Apr
Practice notes
This Practice Note provides a broad overview of the application of Foreign Account Tax Compliance Act (FATCA) to employee incentive arrangements in...
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9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 9th Apr
Practice notes
This practice note provides a broad overview of the application of the Foreign Account Tax Compliance Act (FATCA) to fund structures in the UK.Where...
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Produced in partnership with Andrew Prowse of Fieldfisher 9th Apr
Practice notes
The Foreign Account Tax Compliance Act (FATCA) has three core elements:•enhanced due diligence•broader information reporting, and•a potential...
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Produced in partnership with John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 9th Apr
Practice notes
The Hiring Incentives to Restore Employment Act (the HIRE Act) include provisions that give the US Internal Revenue Service (the IRS) administrative...
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Produced in partnership with John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 9th Apr
Practice notes
On 18 March 2010, the Hiring Incentives to Restore Employment Act (the HIRE Act) was signed into law.The provisions of the HIRE Act that address...
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Produced in partnership with John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 9th Apr
Practice notes
This tax 'tracker' tool displays the current status of both US FATCA and UK FATCA intergovernmental agreements (IGA).The tracker is split into five...
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9th Apr
Practice notes
What are the CDOT agreements?The UK entered into agreements with its three Crown Dependencies (CDs) (Guernsey, Jersey and the Isle of Man), together...
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Produced in partnership with Ali Kazimi of Hansuke 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 9th Apr
Practice notes
This Practice Note provides a brief introduction to Tax Information Exchange Agreements (TIEAs). For a general introduction to the subject of tax...
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9th Apr
Practice notes
STOP PRESS: The government has enacted amending regulations that significantly restrict the scope of the UK’s disclosable arrangements rules (which...
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9th Apr
Practice notes
This Practice Note provides an introduction to the Organisation for Economic Co-operation and Development (OECD)’s Multilateral Convention on Mutual...
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9th Apr
Practice notes
This Practice Note considers the application of the Foreign Account Tax Compliance Act (FATCA) to UK Trusts, as implemented in the UK by the...
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Produced in partnership with Jason Collins and Catherine Robins of Pinsent Masons 9th Apr
Practice notes
Background to FATCAFATCA is so-called because it derives from the Foreign Account Tax Compliance provisions in Subtitle A of Title V (offset...
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Produced in partnership with White & Case 8th Apr
Practice notes
This Practice Note provides a broad overview of the application of the Foreign Account Tax Compliance Act (FATCA) to loan agreements in the United...
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Produced in partnership with Paul Harrington of White & Case LLP 29th Mar
Practice notes
The Foreign Account Tax Compliance Act (FATCA) has three core elements:•enhanced due diligence•broader information reporting, and•a potential...
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Produced in partnership with Orrick, Herrington & Sutcliffe 5th Mar
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
Read More >
Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 1st Mar
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
Read More >
Produced in partnership with David Klass of Hunton Andrews Kurth 1st Mar

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