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U.S. Perspective on Intercompany Cross-Border Loans – Follow Best Practices and Avoid Unintended Consequences

When funds are moved through a corporate group, whether to fund an acquisition or the working capital needs of an affiliate, the transfers may be recorded as book-entry advances and not documented or documented at a later...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Luxembourg Infrastructure Investment Vehicles - New Brochure - The Association of the Luxembourg Fund Industry (ALFI) has issued new technical guidelines regarding “Luxembourg Infrastructure Investment Vehicles”,...more

Tax Newsletter - March/April 2015 (China & Hong Kong)

In This Issue: The People's Republic of China: - China Tightens Tax Control Over Cross-Border Intercompany Payments - China Provides Further EIT Incentives For Integrated Circuit Industry - Expansion of...more

Formation of Private Equity and Venture Capital Funds

The Cayman Islands has long been the most prominent offshore jurisdiction through which to structure offshore private equity and venture capital funds. Why the Cayman Islands? The attractions for international...more

European Commission Launches Action Plan to Review EU Corporate Tax Framework and Close Tax Loopholes

The European Commission’s Action Plan for Fair and Efficient Corporate Taxation in the EU sets out proposals aimed at making corporate taxation in the EU more transparent and efficient, by reforming a system which is seen as...more

FATCA: Making First Submissions and Maintaining Compliance

While the Foreign Account Tax Compliance Act (FATCA) became law in 2010, it has been slowly transitioning to implementation, with 2015 being the first year of required reportings. For anyone not familiar with the Act, FATCA...more

Ticking all the Right Boxes! Irish Collective Asset Management Vehicles Act 2015 Signed into Law

The eagerly anticipated Irish Collective Asset-management Vehicles Act 2015 (the “ICAV Act”) was signed into law in March 2015 and the first Irish Collective Asset-management Vehicles (“ICAVs”) have been authorised by the...more

Proposed U.S. Model Treaty Provisions May Dramatically Alter International Tax Landscape

The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners...more

Revised Property Transfer Tax Return Form Requests Additional Information About Hidden Buyers of New York City Real Estate

In February, the New York Times published an 8,000-word investigation into wealthy foreigners buying New York City real estate and taking advantage of U.S. laws that allow them to set up shell companies in order to obscure...more

Foreign Citizen Living In the U.S.? Remember Your FBAR

If you are a foreign citizen that is considered to be a resident for U.S. income tax purposes, you need to be aware that your U.S. tax filing obligation is not limited to the income tax return. U.S. taxpayers (including...more

Outbound IP Transfer in an F Reorganization

In one corner, we have Code §368(a)(1)(F) which generally allows for a corporation to move from one jurisdiction to another without triggering gain or other immediate adverse income tax consequences. The purpose is to allow...more

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

Three Acquitted In UK Trial For Alleged Nigerian Corruption

On May 27, a London jury found three employees of Swift Technical Solutions Ltd (Swift) not guilty of corruption charges in connection with alleged corrupt payments to tax officials in Nigeria. The SFO announced the verdict...more

Taking Your Business International

Going international is a complicated undertaking. The steps required will depend on your specific situation and concerns. The following outlines, in very general terms, some of the issues you must consider as you begin to...more

New Requirement to File BE-10: Benchmark Survey of U.S. Direct Investment Abroad

Any U.S. person with a foreign affiliate is required to file the 2014 Form BE-10, Benchmark Survey of U.S. Direct Investment Abroad by June 30, 2015 or face civil penalties between $2,500 and $25,000. Further, a willful...more

BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement [Video]

Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more

Impending Deadline for Bureau of Economic Analysis Surveys May Cause Unprepared U.S. Companies to Be Subject to Penalties

Every five years, the U.S. Bureau of Economic Analysis of the U.S. Department of Commerce (BEA) conducts a “benchmark” survey regarding U.S. direct investment abroad by country and industry. The purpose of the survey is to...more

Locke Lord QuickStudy: Validus Court of Appeals Decision - Wholly-Foreign Retrocessions Not Subject to Federal Excise Tax

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

Is it US taxable income? Unintended consequences when US residents receive assets from their family’s foreign corporations

It is not uncommon for affluent families from certain countries to maintain offshore structures to hold a portion, and often times a significant portion, of their wealth. The reasons for holding assets outside of their...more

Treasury Releases Select Draft Provisions for Next U.S. Model Income Tax Treaty

The Treasury Department announced draft changes for the U.S. Model Income Tax Treaty — the baseline text used by the Treasury Department when it negotiates tax treaties. The current U.S. Model was last updated in 2006. The...more

OECD Discussion Draft on Cost Contribution Arrangements vs. US tax rules on Cost Sharing Arrangements: key comparisons

The OECD has released a Discussion Draft on Cost Contribution Arrangements (CCAs) as part of its ongoing activities related to eliminating Base Erosion and Profit Shifting (BEPS) by multinational enterprises. This...more

International tax and withholding considerations for US companies and their directors

To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings...more

Diverted Profits Tax: counterbalancing the UK's "open for business" agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of...more

Coming to America Part II: Legal & Cultural Challenges for Emerging Companies

In our last post “Coming to America Part I,” we discussed why emerging companies would choose enter the US market to do business. In this post, we will discuss the many interrelated legal and cultural factors non-US companies...more

China’s Tax Authority Issues New Circular to Regulate Payment to Overseas Affiliates

On July 29, 2014, the State Administration of Taxation (SAT) of the People’s Republic of China (PRC or China) released The Notice Regarding the Launch of Tax Anti-Avoidance Investigations on Remittance of Substantial Amounts...more

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