The release of the much anticipated final “repair” regulations (Treasury Decision 9636) in September probably stands as the most significant federal tax development of 2013. At over 200 pages in length, the regulations cover a gamut of capitalization questions that are expected to affect nearly every taxpayer.

Draft Finance Bill 2014 was released today with a number of changes that will be important for businesses to recognise. A&M Taxand UK will be responding to the UK Tax Authorities with suggested improvements. This consultation process functions effectively and we ask clients to send us any submissions that they would like us to take forward by the deadline of 4 February 2014.

Various factors such as the growing complexity of U.S. tax laws and compliance obligations, looming corporate tax reform at home and abroad, and the growing role of international operations have made year-end planning more complicated with every passing year. This edition of Tax Advisor Weekly highlights some of the technical developments that occurred in 2013 and important deadlines for 2014, but at the same time provides an approach that tax departments can follow as they tackle year-end planning for their company.

As 2013 comes to an end and our thoughts turn to the holidays, here are a few compensation planning opportunities that should be considered.

Remaining competitive from a tax perspective is a top priority for the UK but the Tax Authorities are also seeking to increase tax revenues where possible.

Everyone loves a good deal, and the only thing better than a good deal is a great deal. Since the enactment of the federal income tax in 1913, certain taxpayers have looked for ways to structure their affairs to get a great deal for tax purposes.

Anticipated changes in the U.S. tax code led to what many thought would be a short-lived spike in dividend recapitalizations in late 2012. Instead, dividend recapitalization activity surged again this year. The appetite of the debt markets has remained strong, leading to favorable pricing and loan terms. Dividend recapitalization transactions totaled $60.2 billion in debt by October 18, 2013, versus $56.4 billion in all of 2012

Given the many restrictions under UK taxation law for interest deductions (anti-arbitrage, Worldwide Debt Cap, unallowable purpose etc.), the UK Tax Authorities are now offering an informal clearance process alongside Advance Thin Capitalisation Agreements (“ATCAs”). This will run alongside the more formal ATCAs to provide much needed certainty in uncertain tax times.

Did you know that Treasury and IRS officials appear close to issuing newly proposed Treasury regulations that could significantly impact the way partnership debt is characterized and allocated?