On Nov. 22, UK Chancellor Phillip Hammond announced dramatic changes to the UK real estate market in the 2017 Budget. The Government has announced an intention to extend the scope of UK tax so that disposals of all UK commercial and residential property by non-resident companies, JPUTs, individuals, and other persons are subject to UK … Continue Reading
On July 13, 2017, the U.S. Tax Court, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner,1 rejected the long-standing Internal Revenue Service (IRS) position that a non-U.S. person is taxed on the sale of an interest in an entity that is a “partnership” for U.S. federal income tax purposes (hereinafter, a partnership) … Continue Reading
The United States Department of the Treasury’s Community Development Financial Institutions Fund (CDFI) has last week announced $7 billion in New Markets Tax Credit (NMTC) awards with the goal of economically revitalizing low-income communities across the country. Particular outcomes that the CDFI hopes to achieve with this round of awards include investment in nonmetropolitan areas, … Continue Reading
Dual American-Israeli citizens finally need to pay up. After years of the US Internal Revenue Service gradually baring down on American citizens living in Israel who evaded reporting income or paying taxes and numerous rounds of amnesty for those belatedly coming forward, September 30 has passed and a new Israel-US agreement has gone into effect … Continue Reading
Come the end of September 2016, the Israeli Tax Authority will start forwarding data collected on U.S. citizens and green card holders with financial accounts in Israel to the U.S. Internal Revenue Service (IRS). This transferring of information is part of FATCA (the U.S. Foreign Account Tax Compliance Act of 2010), based on an agreement between … Continue Reading
On Aug. 1, 2016, the Israel Tax Authority announced that it has received information on over 8,000 Israeli clients with foreign bank accounts in Switzerland. The receipt of this list has major tax implications for Israeli citizens who are required to report foreign bank accounts to the Israel Tax Authority. Moreover, this will have additional … Continue Reading
Section 338(h)(10) of the Internal Revenue Code can provide significant tax benefits to a buyer of 80% or more of a target corporation. A 338(h)(10) election allows a buyer of stock of an S corporation or a corporation within a consolidated group to treat the transaction as an acquisition of 100% of the assets of … Continue Reading
One of the most common tax-related concepts that arises in discussions with employees in connection with the issuance of restricted stock is a Section 83(b) election. So, what exactly is an 83(b) election and how is it helpful to an employee? Section 83 of the U.S. tax code establishes a time frame in which restricted … Continue Reading
Introduction When reviewing U.S. stock option plans for our foreign clients, we are constantly asked to explain the difference in tax consequences between incentive stock option (ISO) plans and nonqualified stock option (NSO) plans. This is a frequently asked question as many U.S. companies offer their employees options to buy company stock at a specified … Continue Reading
If you ask the typical American tax administrator to name a notorious tax haven they would probably name the Cayman Islands or the British Virgin Islands or some other small nation that makes a disproportionate amount of its budget by accommodating international tax structures. Ask the same question of a European tax administrator and the … Continue Reading
Known to many as the “Start-up Nation,” Israel has also been dubbed “Silicon Wadi”; ranking 7th amongst all countries in venture capital activity outside of the U.S. In 2015 alone, there were 326 VC investments in Israel, approximately 60% of which were in the information technology sector. In a recent article entitled Inside Silicon Wadi: … Continue Reading
A common question that we are constantly asked by Israelis and other international clients interested in forming a corporation in the United States is what value we should use for the corporation’s par value. In addition, during the course of performing diligence on a target U.S. corporation, there are always references to the par value … Continue Reading
The highway funding bill recently signed by President Obama, is aimed at aiding the collection of tax debts. Any US citizen with a debt of more than 50 thousand dollars to the IRS, whether living in or outside of the US, could face revocation of his passport, a refusal to renew it, or imposition of … Continue Reading
Things can go cataclysmically wrong for offshore fund managers investing in the United States in the most unexpected manner, at the most unexpected time. A complete list of potential fund-manager tsuris is beyond the scope of this Alert. However, one issue that routinely keeps fund managers awake at night is the specter of their funds’ … Continue Reading
With the establishment of the Prime Minister’s Office Israel-China Task Force in March, led by the National Economic Council and the Israel Export Institute, it is expected that the bilateral economic ties between China and Israel will greatly increase. Greenberg Traurig, with offices in both Tel Aviv and Shanghai, is in a unique position to provide its … Continue Reading
On January 2, 2013, President Obama signed the “American Taxpayer Relief Act of 2012” into law. The Act imposes an income tax increase to 39.6% (from 35%) on U.S. taxpayers earning more than $400,000 ($450,000 for married couples filing jointly) and raises the estate tax rate to a maximum of 40% (from 35%). The federal income tax rate on long-term capital gains has been increased from 15% to 20% for the top income-earners beginning in 2013.… Continue Reading
