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Criminal Finances Act 2017 – New Criminal Offence Requires Preventive Procedures

by McDermott Will & Emery on

The UK Criminal Finances Act 2017 recently introduced a new corporate offence of failure to prevent the facilitation of tax evasion. Under the new law, a corporate body or partnership may be criminally liable if it fails...more

Checking The Box, Partnership Allocations, And Foreign Law

by Farrell Fritz, P.C. on

Many of our clients, most of which are closely-held U.S. businesses, are looking to expand their operations overseas. Some are venturing into foreign markets on their own, while others are joint-venturing with established...more

TechConnect - Your Law Firm Link to Industry News - September 2017

by Mintz Levin on

Letter from the Editors - Words are very powerful and the language we use often frames a discussion. For example, the term “shareholder activist” sounds like a consumer friendly person who has everyone’s best interests at...more

M&A Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more

September 2017: An Update on UK Tax Disputes Including the New UK Corporate Criminal Offense: What Is It and What Should You Do...

Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more

Anti-Inversion Regulations Held to Violate Administrative Procedure Act

by King & Spalding on

On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more

The proposed US tax reform: repatriation alternatives for multinationals operating in Latin America

by DLA Piper on

The proposed US tax reform may incentivize multinational companies that have made investments in Latin America to pursue repatriation alternatives such as dividend distributions and capital reduction. However, the...more

Finland: Supreme Administrative Court decides two transfer pricing cases involving intra-group services - key takeaways

by DLA Piper on

Finland's Supreme Administrative Court has published two new precedential decisions regarding transfer pricing rules, KHO:2017:145 and KHO:2017:146. Transfer pricing related rulings are in short supply in Finland and thus...more

Republican Leaders Release Tax Reform Framework

by McDermott Will & Emery on

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on tax reform. This outline will serve as a useful framework in structuring what will be an active, and...more

State and Local Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on federal tax reform. The states conform to the federal tax laws to varying degrees and the extent to...more

Republicans release new tax reform framework

by Dentons on

On September 27, 2017, the Trump administration and Republican leaders in Congress released their "Unified Framework for Fixing our Broken Tax Code." This nine-page document is the result of months of meetings on tax reform...more

Tax Reform Update: Administration and Congressional Officials Unveil Framework

by Latham & Watkins LLP on

The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details. On September 27, a group of Trump Administration and Congressional leaders...more

President Releases Tax Reform Framework

by Ropes & Gray LLP on

On September 27, 2017, the White House and a group of congressional leaders, commonly referred to as the “Big Six”, released a joint framework for proposed tax reform. The framework sets out five goals: middle-class tax...more

Investor-Friendly Tax Treaty Set for Mexico and Spain

by Jones Day on

The Situation: A Tax Treaty developed to avoid double taxation, negotiated between Mexico and Spain in late 2015, was just recently published in the official gazettes of both nations. The new protocols are effective September...more

Hong Kong releases Consultation Report on Measures to Counter Base Erosion and Profit Shifting: key topics

by DLA Piper on

The Hong Kong government, represented by the Financial Services and the Treasury Bureau (FSTB) and the Inland Revenue Department (IRD), has released its Consultation Report on Measures to Counter Base Erosion and Profit...more

2018 Dutch Tax Plan - changes to Dutch dividend withholding tax

by DLA Piper on

The Dutch Ministry of Finance has published the 2018 Budget and, in connection with it, the 2018 Tax Plan. The 2018 Tax Plan contains a number of already anticipated changes to Dutch tax legislation effective as of January 1,...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

by McDermott Will & Emery on

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

UK Tax Round Up - September 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

New Extra-Territorial UK Corporate Criminal Offence of Failing to Prevent Tax Evasion

by Goodwin on

A new corporate criminal offence of failing to prevent the facilitation of tax evasion takes effect on 30 September 2017. Corporates in both the UK and abroad will incur strict liability if their employees or other associated...more

Draft Legislation Published on UK Partnership Taxation

by Goodwin on

Earlier this year, HM Revenue & Customs published various ideas to ‘clarify’ the tax treatment of partners in partnerships, as part of its response to a consultation on changes to the taxation of UK partnerships. Draft...more

VAT In the UAE - What Your Business Needs to Do

by Bracewell LLP on

The UAE will introduce value added tax (“VAT”) at the rate of 5% from 1 January 2018. The basic principle underpinning the introduction of VAT is to further improve the economic base of the UAE. This is a significant...more

UK Enacts New Offences of Corporate Facilitation of Tax Evasion

The Criminal Finances Act 2017 (the Act) will enter into force in the UK on September 30, 2017, creating new corporate criminal offences in respect of the facilitation of tax evasion. Adopting the same approach as the offence...more

New guidance to register as “privileged” domestic or foreign investment fund under German investment taxation law

by Dechert LLP on

Pursuant to the new German investment tax act (GITA) that will take effect of 1 January 2018, domestic and foreign resident investment funds may become subject to German corporate income tax with various German source income...more

Disallowance of Deduction for Interest Paid to Hungarian Affiliate Serves as a Reminder of Department’s Continued Audit Scrutiny...

by Reed Smith on

A case recently resolved at the Appellate Tax Board serves as a reminder that Massachusetts’ auditors continue to aggressively challenge the following intercompany transactions: - Interest deductions for interest paid to...more

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