General Business International Trade Tax

Read need-to-know updates, commentary, and analysis on General Business issues written by leading professionals.
News & Analysis as of

Analysis: The Tax And The City Briefing For July

Redemption payments - The Court of Appeal (CA) has made short work of a case where loan stock was issued without interest but with a right to redemption proceeds of 7.25% per annum on the principal amount. The outcome is...more

Tax Newsletter - May/June 2014 (China & Hong Kong)

Editorial Note: Welcome to our redesigned Tax Newsletter. You will notice we have streamlined the publication and will now publish bi-monthly instead of quarterly. For major developments that may be highly...more

SEC Issues Interpretive Advice About Verification Safe Harbors Under Rule 506(c)

The availability of the private placement exemption under SEC Rule 506 depends in large measure upon determinations that purchasers are “accredited investors” under the rules. Where there is no general solicitation, Rule...more

Focus on Private Equity - July 2014

In This Issue: - Latin American Private Equity on the Rise - Tax Considerations When Acquiring Non-U.S. Portfolio Companies—Mitigating Subpart F Inclusions - Private Equity Funds at Higher Risk of...more

Italian Government Enacts Innovative Measures to Support Access to Finance

A new decree expands the types of entities allowed to provide loans beyond banks and financial intermediaries. Introduction - The Italian Government enacted law decree No. 91, of June 24, 2014, published on...more

Focus on Tax Controversy and Litigation - July 2014

In this issue: - Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing - Court Determines Tax Analysis not Protected by Attorney-Client Privilege and Work Product Doctrine...more

Doing Business in Canada: Investment Incentives

INVESTMENT INCENTIVES - Generally, Canadian companies are expected to be self-supporting, but for companies involved in export development, there are several types of investment incentive programs which are designed to...more

Real Estate Investment in Australia

Australia continues to be viewed as a destination of choice for global real estate investors seeking a safe haven in a well-regulated and highly transparent growth-orientated market for doing business. In addition, the...more

A Guide to the Cyprus Holding Company Regime

Why set up a holding company? In essence, holding companies are set up as an effective means of consolidating ownership of operating subsidiaries. Deciding where to set up a holding company is not always a tax driven...more

Time For a New Home?

The high number of companies, mostly U.S., eyeing acquisitions or ventures that will allow them to redomicile their business in the UK and Ireland is a major theme of this report. Mostly, it is about tax. But there is quite a...more

Neues BFH-Urteil zu Art. 1 Abs. 7 DBA-USA

Transparente US-amerikanische S-Corporation kann Schachtelprivileg in Anspruch nehmen. Erstattungspraxis noch fraglich. In einem aktuellen Urteil hat sich der BFH erstmals mit Art. 1 Abs. 7 des neuen, seit 2008...more

New judgment on tax treaty between Germany and the US

Hybrid US S-Corporation eligible for participation exemption. Refund practice of taxes withheld remains to be seen. In a recent judgment (file no. I R 48/12), the German Federal Fiscal Court has commented on Art. 1...more

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement...more

CBSA Announces Mid-2014 Audit Targets

As is its practice, the Canada Border Services Agency recently announced its semi-annual trade verification targets for the balance of 2014. Many targets continue from the past, while new ones have been added....more

Introduction of the Exploration Development Incentive

In the 2014 Budget, the Federal Government announced that it would introduce Exploration Development Incentive (EDI) tax credits to encourage and stimulate growth in the junior mining industry. This is a simpler approach to...more

Department of Commerce Announces Preliminary Decision to Impose Tariff on Solar Panels Imported From China

Some U.S. solar equipment manufacturers have lauded the Department of Commerce’s recent decision to impose high tariffs on solar panels imported from China as the end of China’s unfair market advantage; however, from the...more

German Federal Government Plans Tax Exemption of INVEST – Subsidy for Venture Capital

The German Federal Government has given an important insight to its plans and future measures regarding taxation of the start-up- and VC-ecosystem in Germany by officially answer to a parliamentary request by several members...more

M&A Update | Inversions: The View from Ireland

On June 25, 2014, Ireland’s Taoiseach (Prime Minister) Enda Kenny and Minister for Finance Michael Noonan, among others, met with Cadwalader Chairman-elect and Corporate Group Co-Chair James C. Woolery in Dublin regarding...more

United States Prevails in WTO Dispute Challenging China's Duties on U.S. Automobiles

Last month, a World Trade Organization (WTO) Panel issued a report favorable to the United States, ruling against Chinese duties on American auto exports. China had imposed tariffs on U.S. cars and SUVs with engine capacities...more

Tax authorities updated their interpretation of certain transfer pricing issues

On 1 July 2014, the Ministry of Revenues and Levies of Ukraine has issued Order #368 "On amendment of Generalized tax consultation on transfer pricing related issues, adopted by the order #699" (hereinafter - the Order) which...more

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

The IBC Act – the building of a nation

Although nobody knew it at the time, the inception of the BVI’s International Business Company Act occurred at some point during the year 1976. Nobody now recalls the exact date, except that it was during the summer.It is...more

Japan To Reduce Corporate Income Tax Rate

The corporate income tax rate in Japan is known to be one of the highest worldwide. To encourage foreign companies to do business in Japan and make Japan a more attractive location for investments, Prime Minister Shinzo Abe...more

Orrick's Derivatives in Review - July 2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

International Tax News - June 2014

NEW FOR SUPPLIERS OF DIGITAL CONTENT AND INTANGIBLES: DLA PIPER’S GLOBAL VAT GUIDE - Starting January 1, 2015, EU VAT rules for suppliers of digital content, telecommunications and broadcasting services are changing....more

445 Results
|
View per page
Page: of 18

Follow General Business Updates on: