United States: M&A Update: Treasury Announces New Anti-Inversion Rules

On September 22, 2014, the Treasury Department announced its intent to issue new regulations that will reduce the tax benefits available after an inversion and may make it more difficult for some U.S. companies to invert (the “Notice”). The Notice does not require congressional action and applies immediately to all inversions completed after September 21, 2014.
Overview
1. The Notice prevents inverted companies from accessing their foreign subsidiaries’ earnings while deferring U.S. tax through “hopscotch” loans.

U.S. multinationals […]

By |September 24th, 2014|

United Kingdom: Foreign Account Tax Compliance Act And Trusts

Key questions to ask yourself
What are the potential obligations under the UK/US intergovernmental agreement which implements a financial reporting regime in response to the US-Foreign Account Tax Compliance Act (FATCA) rules? Here is a simplified summary of key questions.

FATCA is only the first of many agreements that will come into place over the next few years. UK resident trusts that are deemed ‘reporting financial institutions’ for FATCA purposes will need to report information to […]

By |September 23rd, 2014|

Australia: Impact of the repeal of the Mining Resources Tax on small business

The Mining Resources tax was implemented to get big business funding a larger share of the Federal tax revenue bucket. Now that this has been repealed there are a number of additional measures that have changed which may impact on small business.

The major changes are –

Repeal of company loss carry back rules
Freezing of rate of compulsory superannuation contributions
Changes to immediate asset deductions for small business

For more detail on how these can impact on your […]

By |September 21st, 2014|