Tax

This Note provides an overview of certain key financial accounting (book) and US federal income tax (tax) considerations when accounting for M&A transactions.

This Note discusses the US federal income tax classification rules that apply to foreign businesses. For the US federal income tax classification rules that apply to US businesses, see Practice Note, Choice of Entity: Tax Issues.

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.

This Note discusses the relevant criteria for determining whether a particular security is classified as debt or equity for US federal income tax purposes.

This Note discusses the US federal income tax consequences of owning debt securities of a foreign corporate issuer.

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

This Note provides an overview of the significant US federal income tax consequences of moving or dissolving a US corporation within a US corporate group.

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

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. 

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.

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 Note provides an overview of typical preferred stock features in a private equity or venture capital transaction and discusses the significant US federal income tax issues the sponsor must consider when structuring the preferred stock investment.

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

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 Note provides an overview of tax-free acquisitive reorganizations. Acquisitive reorganizations are transactions where one corporation acquires the stock or assets of another corporation.

This Note discusses the US federal income tax rules that apply to US C-corporations and their US stockholders including the tax issues and rules at formation, during operations, on an asset distribution or sale, on a stock dividend, sale or redemption, and on liquidation.

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

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

This US anti-avoidance measure was introduced by the American Jobs Creation Act 2004. It can affect US taxpayers who participate in UK share plans. UK companies may need US tax advice to ensure their share plans do not cause problems for any employees who are US taxpayers.

This Note provides an overview of the ways a company can mitigate the risks of transfer pricing adjustments under IRC Section 482.

This Note provides an overview of the requirement under health care reform that employers report the cost of employer-sponsored health coverage to employees on Form W-2. It describes which employers must comply, the coverage that must be reported and the method for calculating the cost of coverage.

A discussion of tax-free reorganizations and other types of tax-free transactions in public merger transactions, including links to recent deals summarized in PLC What's Market. This Note will be updated quarterly.

This overview summarises the tax issues for a UK-based multinational wishing to move its tax residence from the UK, and explains how this can be achieved in practice. It covers reasons for corporate emigration, migrating an existing company, introducing a new holding company, post-implementation reorganisations and dividend access arrangements.

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.

A US federal income tax sharing agreement (sometimes referred to as a tax allocation agreement) to be used by a consolidated group of US corporations that includes a US parent corporation and its wholly owned US subsidiaries.  It is drafted with terms favorable to the US parent corporation but aims to be reasonable and contains provisions commonly included. This Standard Document has integrated notes with important explanations and drafting and negotiating tips.

Typical tax clauses in a loan agreement. These Standard Clauses have integrated notes with important explanations.

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 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 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 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.

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.

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.

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.

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 New York. 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 Pennsylvania. 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 Virginia. This Q&A addresses key areas of sales and use tax law such as tax scope, multi-state transactions and collecting taxes and filng returns.

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 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 the United States. The Q&A gives a high level overview of tax in the United States 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 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.

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 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 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 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 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 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 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 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 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 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 the British Virgin Islands. 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 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 the United States (Federal). 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 tax on finance transactions in Spain. This Q&A provides a high level overview of finance tax in Spain 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 Brazil. This Q&A provides a high level overview of finance tax in Brazil 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.

This article provides an overview of the steps taken concerning internationally agreed standards of tax information exchange and disclosure. National incentives to reduce the use of IFCs to avoid tax are considered (with a focus on FATCA), and the future role of IFCs is considered. 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

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

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.

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

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 Article discusses the potential impact of 2013 scheduled tax law changes on business transactions.

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 sales and use tax law in Arizona. 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.

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

A Q&A guide to tax on corporate transactions in Estonia. The Q&A gives a high level overview of tax in Estonia 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.

An article about recent developments relating to the US Foreign Account Tax Compliance Act.

This Article explains how the federal New Market Tax Credit (NMTC) Financing Program works to encourage private investment in low-income areas. It also highlights the benefits and drawbacks for investors and borrowers.

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.

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.

This article examines the taxation of international pharmaceutical companies in France, analysing the principal areas of contention between the pharmaceutical industry and the French authorities. The potential effects on the development of the generic industry and investment by the pharmaceutical industry are also considered. 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.

A Q&A guide to tax on corporate transactions in Luxembourg. This Q&A provides a high level overview of tax in Luxembourg 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. For a full list of recommended tax law firms and lawyers in Luxembourg, please visit PLC Which lawyer? 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.

This Article provides a summary of required retirement plan amendments that must be adopted by the end of the 2010 plan year and plan document considerations for January 2011 determination letter applications (Cycle E).

An expert Q&A with Donald L. Korb of Sullivan & Cromwell LLP on the new economic substance rules and their potential impact on taxpayers.

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.

This Article describes the new IRS employment tax audit project and suggests actions companies can take if they receive an audit notice.

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.

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 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.

This article examines some of the key legal issues raised by the UBS tax evasion case in the US and the likely impact of the settlement announced in August 2009 on Swiss banking confidentiality.

Skadden, Arps, Slate, Meagher & Flom LLP Memorandum describing IRS guidance on the calculation of amounts includible in income and an employer's reporting and withholding requirements for nonqualified deferred compensation under Internal Revenue Code Section 409A. The Memorandum outlines the highlights of the guidance including the timing of income inclusion and the method for determining the amount included in income. Click here to view full text.

An overview of the principal federal, state and local laws governing labour and employment relations in the US.This article is part of the PLC US Special Report, which was published to mark the launch of PLC's first US services.

An overview of the impact on fund managers and funds of Directive 2003/48/EC on taxation of savings income in the form of interest payments (EC Savings Directive) and the related savings taxation agreements concluded with third countries and associated territories.

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.

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

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 Treasury Department published a second intergovernmental agreement to implement FATCA as outlined earlier in joint statements with Japan and Switzerland.

The US and UK signed an agreement to improve international tax compliance and implement the Foreign Account Tax Compliance Act (FATCA) on September 12, 2012.

An update on a change to an effective date under temporary regulations addressing the treatment of dividend equivalent payments.

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.

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

On September 16, 2011, the IRS proposed rules concerning the classification of credit default swaps (CDS) and other derivatives for tax purposes.

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.

An update on the extension of the Report of Foreign Bank and Financial Accounts (FBAR) filing deadline to June 30, 2012 for certain officers and employees with signature authority over foreign financial accounts.

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.

An update on the IRS release of the final schedule and instructions for certain business taxpayers to annually report uncertain tax positions starting with the 2010 tax year.

An update on the publication of the 2010 Hire Act Protocol by the International Swaps and Derivatives Association (ISDA).

An update on the passage of carried interest legislation in the House.

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

An update on the Foreign Account Tax Compliance Act (FATCA) provisions included in the Jobs Bill to combat offshore tax evasion.

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

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

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. For a full list of recommended tax law firms and lawyers in Hong Kong, please visit PLC Which lawyer? 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.