Business Organization International Trade Tax

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BEPS – are you affected?

Over 100 countries and jurisdictions are collaborating through the OECD to implement measures to tackle base erosion and profit shifting (BEPS). The OECD have set out 15 actions points that aim to equip governments with the...more

Foreign Investment in Australia

Foreign investment is key to Australia’s economic development, and Australia welcomes it. As the fourth largest economy in the dynamic Asia Pacific region, Australia's competitive economy is set for continued expansion...more

Luxembourg CSSF Circular 17/650 - Primary tax offences - In the fight against money laundering, what are your professional...

On 17 February 2017, Luxembourg’s financial regulator (Commission de Surveillance du Secteur Financier – CSSF) issued a circular drawn up with the Financial Intelligence Unit in order to provide...more

German Supreme Tax Court Confirms Capital Income Qualification Under Management Equity Programs – Close to a Breakthrough, But…

The German Supreme Tax Court has confirmed that a close to “market standard” Management Equity Program will be taxed on capital income principles. The decision (court number IX R 43/15) provides comfort with respect to most...more

Tax Reform in 2017? What is in Store for U.S. Businesses

With Republicans in control of the White House and Congress, one of the top priorities is tax reform. President Trump’s tax reform proposal and the House Republicans’ tax reform “Blueprint” suggest many changes to business...more

Section 721(c) Partnership Regulations Arrive Just in Time

On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under Section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some...more

The IRS Targets Thirteen Issues in Its New Compliance Campaigns

On Tuesday, January 31, the IRS announced the rollout of thirteen initial compliance campaigns that will be undertaken by its Large Business and International Division (“LB&I”). These campaigns are part of a broader IRS...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

The Australian Government significantly expands ATO powers to fight multinational tax avoidance: Legislation introduced for 40 per...

Introduction and overview - The Australian Government introduced legislation (DPT legislation) into Parliament on 9 February 2017 to implement a further component (second limb) of the United Kingdom–style diverted...more

Ukraine and USA signs treaty on FATCA (Ukrainian)

On 7 February 2017, the Minister of Finance of Ukraine and the US Ambassador to Ukraine signed a treaty on Ukraine’s performance of the US Foreign Account Tax Compliance Act (FATCA) (the Treaty). According to the Ministry of...more

Birds-Eye View of New Gain Recognition Rules on Transfers of Appreciated Property to Partnerships with Related Foreign Partners

The IRS recently issued extensive regulations under the authority of Section 721(c) that denies nonrecognition treatment for transfer of appreciated property to a controlled partnership (domestic or foreign) by a U.S. person...more

Is Your Customs Compliance BEPS Ready?

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

VAT deductions for active holding companies restricted by CJEU

On 12 January 2017, the Court of Justice of the European Union (CJEU) ruled that the VAT deductions on procured services by a holding company may be limited if such a holding company does not charge its subsidiaries for those...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

Treasury Releases Proposed Rules Implementing Partnership Audit Regime; Awaiting Publication in the Federal Register

On January 18, 2017, the Department of Treasury (“Treasury”) released proposed regulations (REG-136118-15) (the “Proposed Regulations”) implementing the partnership audit provisions of the Bipartisan Budget Act of 2015 (the...more

Doing Business in the UAE

Country Background - Formed on 2 December 1971, the UAE is a federal state of seven emirates comprising Abu Dhabi, Ajman, Dubai, Fujairah, Ras Al Khaimah, Sharjah and Umm Al Quwain. The UAE federal constitution...more

China Tax Newsletter - September / December 2016

Welcome to the latest issue of our Tax Newsletter. In this issue we have covered a number of developments and cases in the PRC and Hong Kong from September to December 2016 which could have legal and tax implications to your...more

Russia: tax law changes as of 2017

On 1 January 2017, a number of amendments to the Russian tax law entered into force. Below we highlight the key amendments applicable to the taxation of businesses in the following areas: 1. Corporate profit tax 2....more

New transfer pricing requirements in Latin America under BEPS

Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and...more

Application of the concept of the person beneficially entitled to (beneficial owner of) income

Dentons’ Russia Tax practice would like to remind that, starting from 1 January 2017, the procedure for confirming entitlement to tax benefits under relevant double tax treaties when paying income to foreign companies from...more

French Finance Act for 2017 and Amending Finance Act for 2016: the Most Important Changes Affecting Businesses

The French Finance Act for 2017 and Amending Finance Act for 2016 were enacted on December 30, 2016 (the “Acts”). The Acts introduce a progressive reduction of the corporate income tax rate (28% instead of 33.1/3%). The Acts...more

Border-Adjustable Taxes under the WTO Agreements

This client alert summarizes the World Trade Organization (WTO) disciplines on border adjustable internal taxes and provides a general framework for assessing any future United States corporate tax plan that incorporates a...more

Changes in tax and customs legislation: novelties in the appeals procedure and certain administrative matters

From 1 January 2017 numerous changes to the tax and customs legislation of the Republic of Kazakhstan has become effective. The majority of these changes were introduced by the Law of the Republic of Kazakhstan dated 30...more

Kyiv Tax Newsletter (Ukrainian)

Subsistence minimum and minimum wage - On 21 December 2016 the Parliament of Ukraine adopted the Law “On the State Budget of Ukraine for 2017” No.1801-VIII (hereinafter, "the Law on State Budget"). The Law on State...more

New IRS Reporting Rule Could Bite Unwary Foreign Investors

There are two main sources of reporting requirements for foreign investors in the United States — the Internal Revenue Service and the Bureau of Economic Analysis. The IRS recently upped its game by requiring reports from...more

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