Tax Talks

The Proskauer Tax Blog

Blog Authors

AB C D E F G HIJ K L M N O PQR S TUVWXY Z

Daniella Abel

Martine Seiden Agatston

Gabriella Ahdoot

Justin Alex

Latest from Tax Talks

Tax Talks

Comparison of the Biden Administration and Senate Finance Committee International Tax Proposals

By David S. Miller, Muhyung (Aaron) Lee, Martin T. Hamilton, Amanda H. Nussbaum, Stuart Rosow & Tony Meyer, Jr.

April 12, 2021

On March 31, 2021, the Biden administration released a factsheet for the “Made in America Tax Plan”. On April 5, 2021, Senate Finance Chair Ron Wyden (D-Ore.) and Senators Sherrod Brown (D-Ohio) and Mark Warner (D-Va.) released “Overhauling International Taxation: A framework to invest in the American people by ensuring multinational corporations pay their fair share” (the “Senate Finance Plan”), a parallel set of proposals to the Made in America Tax Plan. On…

Tax Talks

The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposals

By David S. Miller, Muhyung (Aaron) Lee, Martin T. Hamilton, Amanda H. Nussbaum & Tony Meyer, Jr.

April 5, 2021

On March 31, 2021, the White House released a factsheet describing the “American Jobs Plan”, a $2.3 trillion proposal for infrastructure spending that also contains certain significant tax credits, and the “Made in America Tax Plan”, a tax proposal that would generate revenue to pay for the American Jobs Plan spending. The White House estimates that the Made in America Tax Plan will raise $2 trillion in tax revenue over the next 15 years. The…

Tax Talks

UK Budget 2021

By Catherine Sear & Richard Miller

March 4, 2021

The UK has now been in lockdown, on and off, for the best part of a year. With the COVID-19 vaccination programme now in full swing in the UK, and hopefully with light at the end of tunnel, attention has inevitably turned to the question of “how are we going to pay for it all?”. Sweeping and significant tax rises have been feared and, following last year’s Office of Tax Simplification (OTS) review into capital…

Tax Talks

COVID-19: OECD updates its guidance on residence and permanent establishments

By Stephen Pevsner & Philip Gilliland

February 5, 2021

Background From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk. In April 2020 the OECD published guidance on the impact of COVID-19 on double tax treaties (DTTs), including in relation to tax residence, tie breakers and permanent establishments (reported by us in Tax Talks). When reporting on the previous guidance we…

Tax Talks

Regulations on Executive Compensation Excise Tax (Section 4960) for Tax-Exempt Employer and Their Affiliates Finalized

By Seth Safra, Amanda H. Nussbaum, James Huffman & Katrine Magas

February 2, 2021

Employers that are tax-exempt or have tax-exempt affiliates (for example, a foundation) should pay close attention to a 21% excise tax under Section 4960 of the Internal Revenue Code on certain executive compensation. Final Regulations under Section 4960 are described here. The discussion includes traps for the unwary. Please reach out to your Proskauer contact to discuss how these rules affect your organization.…

Tax Talks

Section 1061 Final Regulations on the Taxation of Carried Interest

By Jeremy Naylor, Amanda H. Nussbaum, Scott S. Jones, David S. Miller, Stephen Severo, Brianna Reed & Kaitlyn L. Flynn-Rozanski

January 14, 2021

On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations [1] (the “Final Regulations”) providing guidance on Section 1061 of the Internal Revenue Code (the “Code”).[2] The Final Regulations modify the proposed regulations [3] (the “Proposed Regulations”) that were released in July of 2020. We previously discussed the Proposed Regulations with a series of “Key Takeaways” in our client alert published here…

Tax Talks

Tax Proposals of President-Elect Biden and Other Prominent Democrats

By David S. Miller, Sean Webb, Amanda H. Nussbaum & Stuart Rosow

January 13, 2021

This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats.…

Tax Talks

Narrowing of UK intermediaries’ DAC 6 reporting requirements

By Stephen Pevsner, Richard Miller & Philip Gilliland

January 5, 2021

On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and in the future. In the last year or so, we have regularly written about DAC 6 in our Tax Talks blog and in our monthly UK Tax Round Up. As a reminder, DAC 6 is the wide ranging…

Tax Talks

Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisions

By David S. Miller, Sean Webb, Amanda H. Nussbaum & Stuart Rosow

December 29, 2020

On December 27, 2020, President Trump signed into law the Consolidated Appropriations Act, 2021 (the “Act”). The Act enhances and expands certain provisions of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). This blog post summarizes the tax provisions of the Act.…

Tax Talks

Court of Appeal decides that Jersey companies were UK tax resident

By Katerina Heal & Stephen Pevsner

December 23, 2020

In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the UK for tax purposes by reason of being centrally managed and controlled in the UK. While of considerable interest, it should be remembered that the question of where a company is centrally managed and controlled is principally one of…

Tax Talks

The Proskauer Tax Blog

Blog Authors

Comparison of the Biden Administration and Senate Finance Committee International Tax Proposals

The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposals

UK Budget 2021

COVID-19: OECD updates its guidance on residence and permanent establishments

Regulations on Executive Compensation Excise Tax (Section 4960) for Tax-Exempt Employer and Their Affiliates Finalized

Section 1061 Final Regulations on the Taxation of Carried Interest

Tax Proposals of President-Elect Biden and Other Prominent Democrats

Narrowing of UK intermediaries’ DAC 6 reporting requirements

Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisions

Court of Appeal decides that Jersey companies were UK tax resident

Stay Connected

Company

Products

Support

New to the Network