Recent insights
Tax – A shake-up looms
Tax Risks associated with nomination clauses in Share Purchase Agreements
Tax risk on equity funded dividends – including pre-completion dividends
US-Chile Bilateral Income Tax Treaty Enters Into Force
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 …
Voluntary Disclosure Program Announced for Pandemic-Related Employee Retention Credits
On Dec. 21, 2023, the IRS announced the Employee Retention Credit Voluntary Disclosure Program (ERC-VDP), which helps eligible taxpayers pay back the …
Tax Court Hampers Funds’ Ability To Exclude Income of Non-Passive Limited Partners From Self-Employment Net Earnings
In Soroban Capital Partners LP v. Commissioner,[1]the Tax Court held that the statutory exclusion from the imposition of self-employment tax does not …
Pandemic-Related Employee Retention Credits: Increasing IRS Scrutiny and Related M&A Considerations
The IRS continues to focus on combating perceived fraudulent claims relating to the COVID-19 pandemic-era Employee Retention Credits (ERCs). On Oct. 19, …
US-Chile Income Tax Treaty Approval Process Continues
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 …
High Court of Australia holds Victoria’s electric vehicle tax invalid; other State taxes at risk
Capital Assets
Tax partners Pamela M. Capps and Howard J. Rothman co-authored the book, Capital Assets, published by BNA in 2022.
Another German Real Estate Transfer Tax reform?
IRS Denies Deductibility of Sell-Side Advisory Fees
In Private Letter Ruling 202308010 (PLR 20230810), the Internal Revenue Service (IRS) determined that a contingent sell-side advisory fee (the Fee) was …
Key contacts
William Arrenberg
Partner, London
Nicolás Martín
Partner, Madrid
Toby Eggleston
Partner, Melbourne
Jinny Chaimungkalanont
Managing Partner, Finance and Restructuring, Asia and Australia, Sydney
Nick Heggart
Partner, Perth
Hugh Paynter
Partner, Sydney
Ryan Leslie
Partner, Melbourne