The recent Merge of Ethereum raises questions about how Ether owners should characterize the transaction, although existing IRS guidance suggests treating as a nonevent.
The UK Government considers significant reforms to bring the UK position on sovereign immunity from direct taxation in line with other comparable countries.
The new corporate Book Minimum Tax contains several nuances worth considering.
The UK's First-tier Tribunal recently held that the treaty shopping provisions in the interest article of the UK-Ireland double tax treaty did not apply to deny a taxpayer the benefit of relief from UK withholding tax on interest payments.
In issuing Notice 2022-37, the IRS has once again extended the phase-in of Section 871(m) withholding guidance for certain transactions, leading to uncertainty for market participants.