While legal, regulatory and tax uncertainty continues to affect financial transactions in digital assets, we are seeing incremental guidance developing on US federal taxation issues. The Infrastructure Investment and Jobs Act (Infrastructure Act), enacted in 2021, amended provisions in sections 6045 and 6045A to clarify and expand the rules regarding the reporting of information on
Crowell & Moring partner Paul Muscutt comments in Economia on the reintroduction of crown preference
In the latest edition of Economia, Crowell & Moring Restructuring partner Paul Muscutt comments on the reintroduction of crown preference and the impact that may have on lending.
The article can be found here.
Going backwards – the reintroduction of crown preference
In an article recently published in Business Money, Crowell & Moring partner Paul Muscutt comments on the issues surrounding the potential reintroduction of crown preference:
http://www.business-money.com/assets/Crowell_Moring_April19.pdf
Disguised Remuneration Schemes and the Loan Charge
A disguised remuneration scheme (DRS) is a tax avoidance scheme, many of which involve artificial remuneration arrangements between an employer and employee. The schemes commonly provide for an employee to be partially remunerated through the company payroll system but with the majority of their remuneration taking the form of a loan. The loan is often funded via a third party (typically an off-shore trust) but, where the loans are never intended to be repaid, HMRC treat the monies advanced as taxable income.
Continue Reading Disguised Remuneration Schemes and the Loan Charge