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GAAR in Poland – effective: June/July 2016

On 13 May 2016, the lower chamber of the Polish parliament (Sejm) enacted changes to the Tax Ordinance Act and certain other acts. Among the changes is the introduction of a general anti-avoidance rule ("GAAR"), an abuse of...more

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

In Wake of the Panama Papers, Treasury Proposes New Reporting Requirements for Foreign-Owned Legal Entities

On May 10, 2016, the Treasury Department issued proposed regulations that, if approved, will require business entities formed in the United States that are owned by a single foreign person to obtain an employer identification...more

New Public Country-by-Country Reporting of Financial Information Proposed by European Commission

Country-by-country reporting (“CBCR”) is one of the OECD BEPS deliverables (under Action 13). It is expected to be a significant tool used by tax authorities’ auditors in evaluating a multinational group’s transfer pricing...more

Potential tax consequences of Brexit from a German perspective

On 23 June, the UK is holding a referendum to decide whether it should leave or remain in the European Union. A vote to leave the EU (the so-called Brexit) would not only have repercussions from a tax perspective for the UK....more

Attention Taxpayers: New IRS Rules May Deem Debt to Be Stock

In April, the IRS proposed rules that would treat debt between related corporations as stock for U.S. tax purposes. These rules would apply to all corporations (including regular C corporations, S corporations, foreign...more

US Treasury Announces Measures to Enhance Anti-Money Laundering, Bank Secrecy Act Compliance and Tax Evasion Rule Compliance

The US Treasury Department put forth several measures to combat money laundering, corruption and tax evasion, in the wake of the so-called “Panama Papers” document leak. First, the US Treasury issued a final Customer Due...more

In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

In a news conference May 6, President Obama addressed recently announced rules and proposed regulations intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more

Doing business inside the UAE’s freezones

If you are considering establishing a business in the UAE, you would be wise to spend time investigating the various idiosyncrasies of the local market. One of the first decisions you will arrive at is where to base your...more

FinCEN Issues Final Rules for Customer Due Diligence Requirements

On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued the final version of its long-awaited “Customer Due Diligence Rules” under the Bank Secrecy Act. The final rules impose a new requirement on...more

UK Finance Bill 2016: Royalty Withholding Tax

Domestic UK law imposes a 20% royalty withholding tax on limited types of payment and on specific categories of intellectual property. This year's Finance Bill expands the scope of intellectual property royalties that are...more

You Skipped OVDP, now the IRS has initiated an Audit

Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income Tax and Bank Secrecy Act...more

India-Mauritius Tax Treaty Amended

The amendments are a result of long-drawn negotiations between the two countries. India and Mauritius signed a Protocol on May 10 to amend the India-Mauritius double taxation avoidance treaty. The Protocol grants India...more

LLCs May Be Right Unless They’re Wrong

As I’ve posted before, I usually advise non-US companies to form a corporation when expanding to the United States. Every now and then, I get some pushback because the non-US company has heard about ‘limited liability...more

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

FinCEN Finalizes Beneficial Ownership Identification Rules

As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more

Key Developments in The Photovoltaic Sector in Italy

In Depth - In 2015, solar photovoltaic (PV) systems in Italy generated 24,676 GWh of electricity, representing 9.1 per cent of Italy’s domestic electricity production and 7.8 per cent of the country’s overall...more

NCA and HMRC to Lead Taskforce to Investigate the Panama Papers

From early 2015, 11.5 million documents belonging to a Panamanian law firm, Mossack Fonseca, were provided to a German newspaper, Süddeutsche Zeitung, who shared them with the International Consortium of Investigative...more

Today’s Panama Papers Release May Require Immediate Action to Mitigate Risk of Criminal Prosecution

Action Item: Today at 2:00 p.m. (EDT), a massive database of information from the leaked “Panama Papers” files will be made public for the first time, identifying the real owners behind over 200,000 offshore companies set up...more

Panama Papers prompt new UK tax evasion offences: top 10 concerns for professionals and corporates

The fallout from the Panama Papers continued with the publication of a further consultation by the UK Government on its proposed corporate tax evasion offence. The offence will introduce criminal liability for organisations...more

Treasury Proposes Fundamental New Limitations on Related Party Lending Transactions – With Retroactive Effect!

The U.S. Treasury Department has very recently and unexpectedly released significant guidance that promises, if finalized, to fundamentally limit the circumstances under which related corporations (and, in some cases,...more

Potential tax consequences of Brexit from a UK perspective

This alert considers the possible impact of Brexit on some key UK tax aspects. However, this is only one side of the perspective: we will shortly be publishing a second article considering the potential impact of Brexit on...more

French 3% contribution tax on distributions: Claim opportunities for French subsidiaries of MNEs following new developments...

On April 6, 2016 the First Instance Court of Montreuil filed a request with the French Constitutional Court in relation to potential breaches of the French Constitution (more precisely the Declaration of Human Rights dated...more

Federal Budget Update

The Australian Government continued its attack on Multinational Tax Avoidance with the release of its 2016-2017 Federal Budget. Central to its Budget initiatives is the introduction of a 40% Diverted Profits Tax on large...more

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