Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
The Italian government recently approved a draft 2024 budget law which provides for the extension of the domestic participation exemption regime on disposal of shareholdings (PEX) to those non-resident corporations that: (i)...more
11/28/2023
/ Corporate Entities ,
Corporate Taxes ,
EU ,
European Economic Area (EEA) ,
Income Taxes ,
Italy ,
Legislative Agendas ,
Member State ,
New Legislation ,
New Regulations ,
New Rules ,
Regulatory Agenda ,
Shareholders ,
Tax Code ,
TIEA
On October 16, 2023, the Council of Ministers approved, in preliminary examination, the draft of a legislative decree implementing the tax reform on international taxation. The draft decree must now acquire the opinions of...more
On October 16, 2023, the Council of Ministers approved, in preliminary examination, the first two drafts of legislative decrees implementing the new “Italian Tax Reform” (Law No. 111/2023).
One of these legislative...more
At its meeting on October 16, the Council of Ministers approved, in preliminary consideration, the first two draft legislative decrees implementing the Reform Proxy Law (Law No. 111/2023):
– the first legislative decree...more
The Judgement -
In its judgment no. 21261 issued on 19 July, the Italian Supreme Court stated that non-resident companies without an Italian permanent establishment (PE) are entitled to apply the Italian 95% participation...more
EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE -
On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more
6/6/2022
/ American Bar Association (ABA) ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Taxes ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
EU ,
European Commission ,
GILTI tax ,
Investigations ,
Member State ,
Model Rules ,
OECD ,
Pillar 2 ,
Sustainability ,
Tax Rates ,
White Collar Crimes
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...more
5/5/2022
/ Asset Management ,
Buyers ,
Charitable Donations ,
Corporate Taxes ,
Cross-Border ,
Donations ,
EU ,
Foreign Tax Credits ,
Germany ,
GILTI tax ,
Global Market ,
Income Taxes ,
International Tax Issues ,
Investment ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Pay-for-Performance ,
Remote Working ,
Sellers ,
Trustees ,
U.S. Treasury ,
UK ,
Withholding Tax
The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more
WHAT IS THE AIM OF PILLAR 2 RULES?
The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework’s project is to ensure that multinational groups of companies pay a minimum level of tax...more
The Italian Digital Services Tax (DST) was introduced as part of the 2019 Italian Budget Law and then amended by the 2020 Italian Budget Law. Among other things, the 2020 Budget Law: (i) provided the applicability of the...more
Proseguendo una consuetudine dello Studio, che ha sempre raccolto l’interesse e l’approvazione da parte Vostra, abbiamo organizzato, quest’anno in formato webinar, un incontro sulle principali novità fiscali recentemente...more
1/18/2021
/ Business Assets ,
Business Taxes ,
Corporate Taxes ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
Italy ,
Revaluation ,
Tax Liability ,
Tax Planning ,
The Patent Box ,
Transfer Pricing ,
UK Brexit ,
Webinars
Continuing a practice of the Firm, which has always garnered your interest and approval, we have organized, this year in webinar format, a meeting on the main tax innovations recently introduced and of interest to...more
1/18/2021
/ Business Assets ,
Business Taxes ,
Corporate Taxes ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
Italy ,
Revaluation ,
Tax Liability ,
Tax Planning ,
The Patent Box ,
Transfer Pricing ,
UK Brexit ,
Webinars
The Coronavirus (COVID-19) has governments across Europe, Asia, Africa, Australia, North and Latin America quickly evaluating and issuing modified tax-related measures to help support business investments and providing...more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets.
Understand how new tax regulations transect...more
6/2/2020
/ Anti Tax Avoidance Directive (ATAD) ,
Business Operations ,
Business Taxes ,
Continuing Legal Education ,
Corporate Taxes ,
Dividends ,
Financing ,
Foreign Corporations ,
France ,
Germany ,
Holding Companies ,
International Tax Issues ,
Italy ,
New Regulations ,
Restructuring ,
Tax Liability ,
Tax Losses ,
Tax Planning ,
Transfer Pricing ,
UK ,
Webinars ,
Withholding Tax
During the Coronavirus (COVID-19) crisis, business may slow down or even completely shut down, sales are down or next to zero, cost cutting programs have already started, and nobody knows exactly when the recovery will...more
The Coronavirus (COVID-19) has governments across Europe, Asia, Africa, Australia, Latin America and the United States quickly evaluating and issuing modified tax-related measures to help support business investments and...more
A recent McDermott round table on European health private equity generated key insights into the future of medtech, digital health, and data analytics, and identified opportunities for companies and investors.
Digital...more
12/20/2019
/ CFIUS ,
Digital Health ,
Digital Services Tax ,
Global Dealmaking ,
Healthcare ,
International Arbitration ,
Life Sciences ,
Medical Devices ,
Outbound Transactions ,
Private Equity ,
State-Owned Enterprises ,
UK Competition and Markets Authority (CMA)
Governments are starting to catch up with online businesses. Multinational clients that provide online advertising services, sell consumer data, or run online intermediary platforms should prepare themselves for the imminent...more
11/13/2019
/ Business Taxes ,
Data Protection ,
Digital Service Providers ,
Digital Services Tax ,
Double Taxation ,
Imports ,
Income Taxes ,
International Tax Issues ,
Jurisdiction ,
Online Advertisements ,
Online Marketplace ,
Online Platforms ,
Personal Data ,
Reimbursements ,
Retaliatory Tariffs ,
Search Engines ,
Social Media ,
Tax Planning
On 26 February 2019, the Court of Justice of the European Union (CJEU) issued long-awaited judgments in a group of cases concerning the Danish government withholding tax on dividends and interest paid by Danish companies to...more
On February 26, 2019 the Court of Justice of the European Union (CJEU) issued the long-awaited judgments on the cases concerning the Danish government withholding tax on dividends and interest paid by Danish companies to...more
3/5/2019
/ Anti-Abuse Rule ,
Beneficial Owner ,
Court of Justice of the European Union (CJEU) ,
Dividends ,
EU ,
Member State ,
OECD ,
Parent Corporation ,
Payment Services Directive ,
Subsidiaries ,
Tax Exemptions ,
Withholding Tax
Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more
8/3/2015
/ BEPS ,
Biotechnology ,
Capital Gains ,
Copyright ,
Corporate Taxes ,
Industrial Design ,
Innovation ,
Intangible Property ,
Italy ,
Medical Devices ,
OECD ,
Patents ,
Qualifying Income ,
Research and Development ,
Software Developers ,
Tax Incentives ,
Tax Rates ,
The Patent Box ,
Trade Secrets ,
Trademarks ,
Utility Patents