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European Commission publishes an EU corporate tax system

Today the European Commission published three corporate tax directives that potentially will apply in 27 Member States (28 - UK) of the European Union. These corporate tax directives include: the Common Consolidated Tax Base...more

Tax Uncertainty Hinders Global Growth: Business Survey Launched

Businesses are invited to participate in an international survey from the OECD to measure the impact of tax uncertainty on their investment decisions. Companies have until December 16 to participate in a confidential...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Using corporate structures to own UK residential property – a dead end?

Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more

Proposed Regs May Limit US Estate Plan

On August 2, 2016, the US Treasury issued long-awaited pro- posed regulations under Code section 2704 that make comprehensive and very significant changes to the valuation of interests in many family-controlled entities for...more

Proposed Amendments to UK Proceeds of Crime and Terrorism Legislation 

A Bill was introduced in the UK Parliament proposing amendments to the Proceeds of Crime Act 2002 and Terrorism Act 2000. The Bill forms part of the UK Government’s Action Plan to counter money laundering and the funding of...more

Inheritance Tax Reform passed – Germany misses chance to tame Tax-Bureaucracy for Family Owned Businesses

Bryan Cave’s Tax law expert Stefan Skulesch: “Last minute solution with flaws will continue to impede company successions in Germany” - On 14 October 2016 the Bundesrat (the upper house of the German parliament) has...more

EU court eases formal invoice requirements for input tax deduction

According to two milestone decisions in September 2016 of the EU Court of Justice (Senatex, case C-518/14 and Barlis 06, case C-516/14) formal invoice requirements for input tax deduction have been eased. Taxpayers should...more

Luxembourg VAT Authorities issue Circular n°7891 on VAT treatment of directors’ fees.

On September 30, 2016, the VAT authorities confirmed that VAT shall apply to directors’ fees. From a VAT standpoint, "any person who carries out in an independent and usual manner any economic activity, whatever the...more

The Luxembourg indirect tax administration confirms the VAT treatment of director fees

On 30 September 2016, the Luxembourg indirect tax administration (LTA) issued a circular n°781 confirming that director fees are subject to VAT (the Circular). As reported in our previous e-alert on this matter circulated in...more

Global Tax News: Brazil opens consultation on how MAP provisions apply to DTT agreements

Brazil’s Federal Revenue (RFB) has opened a public consultation aimed at regulating how mutual agreement procedure (MAP) provisions apply to conventions and international agreements created to avoid double taxation....more

Criminal consequences of the use of leaked data by tax authorities

Leaks of confidential information are becoming more common. Businesses and individuals may face scrutiny by investigative agencies following leaks of information from third parties or by employees. Businesses in particular...more

Global Tax News: Brazil amends lists of tax havens and tax privileged regimes, clarifies "substantial economic activity"

Earlier this month, Brazil’s Federal Revenue (RFB) released Normative Instruction RFB No. 1,658, which amended Normative Instruction RFB No. 1,037/2010 to...more

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

Digesting the €13 Billion Apple-EU Tax Ruling

King & Spalding experts assess what international businesses need to be aware of following the EC's ruling on State Aid in the Apple case - Partners in King & Spalding’s tax department have shared their perspectives and...more

10 Steps to Mitigate EU State Aid Exposure on Tax Arrangements

As the European Commission reviews whether tax arrangements conform with State aid rules, companies active in Europe should ensure their fiscal regimes comply with EU law. In recent years, the European Commission (the...more

Tax Alert for Foreign Investors Looking at U.S. Investments

Pre-immigration and Non-U.S. Resident Planning - It does not matter whether foreign individuals are investing in U.S. property and hoping to become residents in the U.S., or are planning to invest in U.S property...more

Overview of Luxembourg Tax Developments - September 2016 - Issue 01

This report summarizes some of the main Luxembourg tax developments that took place between the end of 2015 and August 2016. The selected developments are mainly relevant to companies and the international tax...more

Canadians Who Invested in U.S. LLPs and LLLPs Need to Rethink Their Choice of Entity

Historically, Canadian investors in U.S. partnerships benefitted from an extremely efficient income tax structure – i.e., a single level of tax, credit against Canadian taxes for taxes paid in the U.S., and an ability to...more

Amendments of CIT and PIT Acts in Poland

On 5 September 2016, the lower chamber of the Polish parliament (Sejm) accepted changes made by the Senate to the Act amending PIT and CIT. The Amendment Act has been sent to the President for signing....more

State aid – the European Commission charges forward

This note provides an update on the EU state aid decisions and aims to put recent developments in context. We review the current state of the state aid investigations, provide some political context, touch on the US...more

Ten Key Legal Issues to Consider When Moving Stateside

Stateside - Even before the uncertainties following the Brexit referendum result, a move to the U.S. was an attractive proposition for high growth UK businesses. Common language, similar culture, access to capital and a...more

EU tax ruling levies €13 billion state aid penalty on Apple

On 30 August 2016, Ireland was ordered by the EC to recover up to €13 billion from Apple on the basis that tax arrangements implemented between Apple and Ireland, originally in 1991, amounted to the provision of unlawful tax...more

The sukuk experience in Turkey

Turkey's government is determined to make Istanbul a financial hub for Islamic finance, regionally and globally. With a GDP of US$733.6 billion in 2015 according to the IMF, Turkey is the 18th largest economy in the world,...more

Battle Heats Up Over Who Can Regulate Tax on International Companies

In a decision that again pits the United States against the European Union in that ongoing battle over which entity can primarily tax international business, Margrethe Vestager, the European Union commissioner for...more

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