International News: Spotlight on Tax - McDermott Will & Emery

International News: Spotlight on Tax



Introduction to US Taxation of NFTs

Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored by the US Internal Revenue Service (IRS) in the agency’s pronouncements on the taxation of cryptocurrencies. Read more.

UK VAT and Withholding Tax Considerations for Impact Bond Structures

Ranajoy Basu | James Ross | Priya Taneja | Sarah Gabbai

Designing the tax structure early on in the process of developing “pay for performance” cross border funding mechanisms is as important as designing clear impact metrics. Read more.

German Tax Aspects of Cross-Border Remote Working

Dr. Gero Burwitz | Dr. Isabella Denninger | James Ross, Paul McGrath, Jilali Maazouz, Abdel Abdellah, Romain Desmonts

As a result of the COVID-19 pandemic, remote working became a necessity. Despite the easing of lockdowns, the trend is likely to stay, particularly with “workations” being actively promoted by the travel industry, but there are considerable tax consequences for international employers. Read more.

New US Treasury Regulations Deny Foreign Tax Credits for Previously Creditable Foreign Taxes

Brian H. Jenn

New regulations adopt a new “attribution requirement” that restricts the availability of foreign tax credits (FTCs) to foreign taxes that the US Treasury and Internal Revenue Service (IRS) consider to be similar to US taxes. Read more.

Relaunching the United Kingdom as the European Centre of Alternative Asset Management

Kevin Cummings

In an attempt to claw back some of the business lost as a result of Brexit, the UK Government has launched a version of the “asset holding companies” (AHCs) that made Luxembourg and Ireland such attractive destinations. Read more.

Trustees and the Need for Reviews

Simon Goldring

A recent case illustrates the importance of regular trust reviews. Read more.

An Overview of OECD Pillar 2

Brian H. Jenn | Annette Keller | Dr. Dirk Pohl | James Ross | Andrea Tempestini | Antoine Vergnat | Romain Desmonts | Alessio Persiani

Potential new tax rules would significantly impact the taxation of multinational groups, introducing new complexity to international taxation and nullifying the benefit of tax incentive regimes employed by many countries to attract foreign investment. Read more.