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September 22, 2022

The recent Merge of Ethereum raises questions about how Ether owners should characterize the transaction, although existing IRS guidance suggests treating as a nonevent.

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The UK Government considers significant reforms to bring the UK position on sovereign immunity from direct taxation in line with other comparable countries.

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The new corporate Book Minimum Tax contains several nuances worth considering.

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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.

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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.  

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