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Mexico 2016 Tax Reform

The 2016 Tax Bill presented by the President to Congress on September 8, 2015 was approved almost in its original terms by both Chambers of Congress on October 29, 2015 and published in the Official Gazette of the Federation...more

IRS Announces Intent to Tax Transfers to Partnerships With Foreign Partners

On August 6, 2015, the IRS issued Notice 2015-54, which states that the IRS and Treasury intend to issue regulations under section 721(c) of the Internal Revenue Code to ensure that, when a U.S. person transfers certain...more

IRS Issues More Anti-Inversion Rules

Following on its prior Notice 2014-52 anti-inversion guidance, the IRS has issued new Notice 2015-79 to further limit (i) inversion transactions that are contrary to the purposes of the Section 7874 anti-inversion rules and...more

Supreme Court of Canada to Hear Tax Rectification Case

On November 19, 2015, the Supreme Court of Canada granted leave to appeal in Canada (A.G.) v. Groupe Jean Coutu (PJC) inc., 2015 QCCA 838, which addresses the question of when rectification will be granted in the tax context....more

Global Tax News - November 2015

HANDS OFF DIGITAL CURRENCIES! CANADA’S SENATE CALLS FOR A LIGHT REGULATORY APPROACH Formerly considered a gimmick for geeks and gamers, digital currencies, such as Bitcoin, have grown into a worldwide phenomenon...more

HMRC Responds to Landmark Case on UK Tax Treatment of Delaware LLCs

Business as usual for UK taxpayers following Supreme Court decision in Anson v HMRC? HM Revenue and Customs (HMRC) has published its response to the UK Supreme Court’s decision in the landmark double taxation case of...more

How to Get in on the Offshore Fund Flow to the U.S.

A recent report estimates that foreign investors are expected to spend more than $70 billion on U.S. commercial real estate in 2015. Another report states that nearly a quarter of all recent commercial real property sales in...more

Proposed Regulations Nix Foreign Goodwill Exception to Tax on Outbound Transfers

The IRS and Treasury recently issued proposed regulations under Section 367 with bad news for taxpayers. Citing aggressive taxpayer positions, the proposed rules do away with the foreign goodwill exception and restrict the...more

Consultation over Fixed Cap on UK Tax Deductibility of Corporate Interest Expense: Plucking the Feather in the Cap?

The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax...more

Abolition of Luxembourg IP Box Regime

On 14 October 2015, the Luxembourg Minister of Finance presented a bill to Parliament on the state budget for 2016. This bill contains several proposals affecting corporate taxpayers. One of the main proposals is the...more

Australian Tax Update - October 2015

The Chevron decision provides critically important guidance on both the 'old' (Division 13) and 'new' (Subdivision 815-A) transfer pricing laws in Australia. While not dealing specifically with Subdivisions 815-B to D, the...more

Fibra E Trusts | Energy and Infrastructure Investment Vehicle

On 29 September 2015, the Fourth Set of Amendments to the Annual Tax Regulations for the 2015 fiscal year (“Tax Regulations”), which create and regulate a new investment vehicle called an energy and infrastructure investment...more

Managing The Changing Tax Landscape: The OECD’s BEPS Recommendations Will Impact Every Multinational

The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that...more

The EC Challenge on Tax Rulings. Why it’s Important that Your Business Acts Now in Relation to EU Challenges to Tax Rulings

21 October 2015: Following state aid investigations, the European Commission has ordered Luxembourg and the Netherlands to recover unpaid taxes of €20-30m from each of Fiat and Starbucks. The Commission has confirmed that...more

Tax Newsletter - July/August 2015 (China & Hong Kong)

Welcome to the latest issue of our Tax Newsletter. As you may be aware, much has happened since our last issue. In this issue, we highlighted a number of developments in both the PRC and Hong Kong that could be of legal and...more

[Event] Tax Advantaged Strategies for Foreign Source Income and Investments: Required Tax and IRS Reporting - Oct. 28th,...

Join us at Coconut Bay Thai Restaurant & Bar and learn about tax strategies geared towards individuals. Light appetizers and good company will be provided! Topics include: Foreign Investment in US Real Estate ...more

New Regulations on F Reorganizations

In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more

New Regulations to the Income Tax Law Enter Into Effect Today

On October 8, 2015, new Regulations to the Income Tax Law were published in the Official Gazette of the Federation. Such regulations became effective as of today, October 9, 2015. The Regulations were mainly issued to...more

[Webinar] Tax Planning for Investments Into Brazil - Oct. 14th, 12:00pm ET

Please join us on Wednesday, October 14th at 12:00pm EST for an in-depth joint presentation by tax attorneys, Jeffrey Rubinger of Bilzin Sumberg and Fernando Martins of WFaria Advogados on the cross-border tax considerations...more

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

Now’s the Time to Review Compensation Arrangements Relating to Unvested Rights

Correction of Errors before Year End Could Avoid Costly 409A Penalties - Sometimes overlooked is the fact that many employment, severance and change-of-control agreements are subject to U.S. Internal Revenue Code...more

Entering the U.S. Without Entering Its Tax System: Holding Company Structures for U.S. Operations

Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits...more

UK tax treatment of US LLC: HMRC’s practice following Anson

We reported earlier this year on the UK Supreme Court’s decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to claim relief against his UK tax liabilities for US tax paid on his share of...more

Tax Policy Update

NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more

Recent UK Court Decision on UK Tax Treatment of US LLCs

HMRC provides guidance on the implications of the recent case Anson v Revenue and Customs Commissioners. Delaware limited liability companies (LLCs) are regularly seen in many international corporate groups, including in...more

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