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The Netherlands proposes changes to dividend withholding tax

by DLA Piper on

The Dutch government has released an attractive proposal to fully exempt withholding tax on dividends paid to non-resident shareholders in treaty countries provided certain conditions are met. Many multinational enterprises...more

Transfer pricing compliance in Russia. Part 3. Stages of transfer pricing compliance

by Dentons on

Dentons’ Tax and Customs practice congratulates its clients and friends on the end of the first stage of transfer pricing compliance for 2016 – the filing of the notification of controlled transactions completed in 2016!...more

Manufacturing Matters May 2017

by DLA Piper on

As mentioned in the last issue of Manufacturing Matters, “Smart Manufacturing”, including automation, is gaining momentum. A number of leading global manufacturers have already adopted it, and according to The Annual...more

Limitation of Corporate Loss Carryforward Affecting Only Particular Share Transfers Declared Unconstitutional

by White & Case LLP on

The Federal Constitutional Court of Germany held that the forfeiture of tax loss carryforwards under Sec. 8c para. 1 sent. 1 CITA is inconsistent with the principle of equal treatment pursuant to German Constitutional Law....more

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

Tax administrations prepare for automatic exchange of CbC reports - are you ready? Three takeaways

by DLA Piper on

OECD announced that another important step has been taken to implement country-by-country (CbC) reporting requirements, as signatories to the Multilateral Competent Authority Agreement on the Exchange of CbC Reports (the CbC...more

Viewpoints - Issue 28 - The Board’s Role in Overseeing Innovation

by King & Spalding on

Innovation has become an essential capability for any large public company if it wants to remain competitive. With some studies suggesting that 50% of the companies in the S&P 500 list could be replaced over the next 10...more

Corporate and Financial Weekly Digest - Volume XII, Issue 18

SEC/CORPORATE - US District Court Holds That Discretionary Tax Withholding is Exempt Under 16b-3 - Several companies have received shareholder letters seeking to recover short-swing profits from insiders under Section...more

Development of court practice of determining direct capital investment for the purpose of applying the 5% withholding tax rate...

by Dentons on

On 3 May 2017 the Commercial Court of Chelyabinsk Region rendered a decision in case No. ?76-20508/2016 under the claim of Chelyabenergosbyt PJSC (the “Company”)....more

Public Mergers and Acquisitions in Canada 2nd Edition - May 2017

by Bennett Jones LLP on

Canadian public merger and acquisition transactions in 2016 (in-bound and out-bound) comprised over C$400 billion in value with at least one-third of the transactions in Canada being fueled by foreign buyers. The second...more

Emmanuel Macron Elected President: French Taxation to Fall in Line with the European Average?

by Dechert LLP on

Following the election of Emmanuel Macron as President of the French Republic, you will find below a few examples of expected tax changes of potential importance to our clients....more

Australian Federal Budget 2017 - 2018

by DLA Piper on

The Australian Government introduces a new major bank levy, increases the costs for foreign owners of Australian real estate and extends Managed Investment Trust concessions to investment in Affordable Housing from 1 July...more

Corporate criminal liability risk increases for financial services

by Allen & Overy LLP on

The Criminal Finances Act 2017, which received Royal Assent last week, contains the largest expansion of UK corporate criminal liability since the Bribery Act 2010 and one of the most significant overhauls of money laundering...more

Russia introduces draft law on country-by-country reporting requirements: implications for multinationals

by DLA Piper on

A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the...more

Update on US Federal Tax Reform Proposals

by Shearman & Sterling LLP on

On April 26, the Trump Administration made its much-anticipated release of several “core principles” of its tax plan. In doing so, the administration affirmed its desire to enact comprehensive corporate and individual tax...more

Trump releases tax plan: now Congress takes its turn

by DLA Piper on

The release this week of the Trump Administration's tax reform principles, along with the disclosure by Speaker Paul Ryan (R-Wisconsin) of a letter from the Congressional Joint Committee on Taxation relative to the budgetary...more

Tax Reform – An Update Based on Recent Statements from the Trump Administration

by Latham & Watkins LLP on

The Trump plan released this week proposes a significant reduction of tax rates applicable to business income (including income earned through pass-through entities) and a territorial system (with a one-time tax on...more

ATO wins Full Federal Court decision on Cross Border Financing - Chevron Australia Holdings case

by DLA Piper on

In a major Australian transfer pricing decision on Friday 21 April 2017, the Full Federal Court dismissed Chevron Australia Holdings Pty Ltd's (CAHPL) appeal related to the deductibility of interest on the Australian dollar...more

Extensions to the double tax treaty passport scheme

by DLA Piper on

The double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under...more

China updates special tax adjustment measures: new rules go into effect May 1

by DLA Piper on

China's State Administration of Taxation (SAT) has released the Administrative Measures on Special Tax Investigation Adjustments and Mutual Agreement Procedures in the Public Notice [2017] No. 6 (Bulletin 6). Bulletin...more

Turning Tides

by DLA Piper on

Ukraine is typically seen as an emerging country, blighted by crisis. Ukrainians are all gradually helping to change this stereotype. Here we examine key legal reforms aimed at improving the efficiency and safety of...more

Dutch Supreme Court refers questions on withholding tax refunds for foreign investment funds to CJEU

by DLA Piper on

The Dutch Supreme Court has referred preliminary questions on Dutch dividend withholding tax refunds for foreign investment funds to the Court of Justice of the European Union (CJEU). The Dutch Supreme Court wishes to clarify...more

Two Important New International Tax Filings

by Charles (Chuck) Rubin on

While not the only international reporting changes that are occurring, there are two significant ones that apply for the current filing season for 2016 returns. First is the FBAR, which reports interests in foreign...more

Kyiv Tax Newsletter (Ukrainian)

by Dentons on

On 23 March 2017, the President of Ukraine signed the Law of Ukraine “On Amendments to the Tax Code of Ukraine Concerning the Taxation of Inheritance” (hereinafter – the Law on inheritance tax), which simplifies the...more

Kyiv Tax Newsletter - April 2017

by Dentons on

On 23 March 2017, the President of Ukraine signed the Law of Ukraine “On Amendments to the Tax Code of Ukraine Concerning the Taxation of Inheritance” (hereinafter – the Law on inheritance tax), which simplifies the...more

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