United States: Treasury And Internal Revenue Service Publish Regulations On Failure To File Gain Recognition Agreements

The Service and Treasury, in T.D. 9704, 2014-50 IRB 922 have published final regulations which clarify, as well as update, the rules on the consequences faced by U.S. and foreign persons for failing to file GRAs or other reporting obligations and resulting penalties under §6038B with respect to certain transfers of property made to foreign corporations in a non-recognition transaction. The Service had previously issued regulations in 2013 (proposed regulations) which required a U.S. […]

By |March 6th, 2015|

Turkey: A Quick Peek On The Novation Or Assignment Of Leases At A Glance

Charge of Lessor in Cross-Border Financial Lease Agreements
Under Turkish law, cross-border financial lease agreements must be registered by the Association of Financial Leasing, Factoring and Financing Companies (“Association”). The same authority registers any amendment made to the prior registered leases. The Association recently changed the practice of their legal predecessors, namely, Banking Regulation and Supervision Agency (“BRSA”).

Last year, the registration of “Novation and Amendment Agreements of cross-border leases”, which only changed the lessor of […]

By |March 5th, 2015|

United States: State Of The Union Or Tax Rhetorical?

In the annual ‘State of the Union’ speech on 20 January, President Obama included a number of new tax proposals that purportedly aim to raise taxes on the wealthy and lower taxes for working families and the middle-class. The additional tax revenue thereby generated would be used to provide two years of community college education free of charge to qualifying students. These are truly noble goals, and both political parties want to help the […]

By |March 5th, 2015|