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China Tightens Individual Income Taxation On Capital Gains From Equity Transfer

China's State Administration of Taxation (SAT) recently promulgated the Public Announcement [2014] No. 67, Administrative Measures for Individual Income Tax on Income from Equity Transfers (for Trial Implementation) (Equity...more

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent...more

New Russian De-Offshoring Rules. The Impact On Foreign Investors And Russian Businesses

The debate over the strength of the de-offshoring initiatives between Russian Government hard-liners and representatives of the business community seems to have been finally resolved as the Russian lawmakers have adopted...more

Canadian Customs Authority Shifts Gears on Import Duty Refunds

The CBSA has made a long-sought-for change in its policy to allow duty refunds in the event of qualifying downward transfer price adjustments by importers. The change comes on the heels of victory by Bennett Jones in a test...more

Important Deadlines and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity...

Investment Advisers - Annual Compliance Reviews: All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least...more

Tax: About the new import duty

On 28 December 2014 Ukrainian Parliament adopted the Law of Ukraine No73-VIII "On Measures on Stabilizing the Balance of Payments of Ukraine According to Article ??? of GATT 1994" (based on the draft law ?1562) and the Law of...more

Seventh Circuit to Motorola: No Rehearing En Banc

On December 1, 2014, we wrote about the Seventh Circuit’s decision in Motorola Mobility LLC v. AU Optronics Corp., which affirmed dismissal of the vast majority of Motorola’s claims regarding LCD panels....more

Australian Tax Alert: Bitcoin And Crypto-Currencies: Why The GST Law Should Change

The ATO released a draft ruling on the GST treatment of bitcoin transactions on 20 August 2014. A final version of that ruling, GSTR 2014/3, was released on 17 December 2014. While the ruling deals specifically with bitcoin,...more

Luxembourg Tax Authorities Confirm Tax Treatment of Limited Partnerships

The Luxembourg tax authorities have confirmed, by means of the long-expected Circular Letter L.I.R. nº 14/4 (the “Circular”), the treatment of tax transparent Luxembourg limited partnerships in the form of a société en...more

IRS Hammers Offshore Lending and Underwriting Structure

In a recent Chief Counsel Advice, in an extended analysis the IRS determined that an offshore partnership with a U.S. manager that was engaged in the finance transactions was determined to be engaged in a U.S. trade or...more

Transfer pricing changes

On December 28, 2014 Ukrainian Parliament has adopted the Draft law No. 1264-1 "On amending the Tax Code of Ukraine regarding improvement of tax control over transfer pricing" as of 22.12.2014 (the Draft Law)....more

Luxleaks - The next level

Until recently, the Luxemburg Government had resisted the European Commission's attempts to disclose the beneficiaries of tax rulings. It had even taken the information injunction to the EU Court of Justice. This has now...more

Proposed Anti-Inversion Regulations Would Affect Foreign Insurers

For decades American companies have used so-called “corporate inversions” to lower their tax burdens on foreign-earned income. Typically, the American company is acquired by a foreign company located in a tax-favorable...more

Delaware Supreme Court Endorses Change of Control Subject Only to a Post-Signing Passive “Market Check” and Overturns Chancery...

On December 19, the Delaware Supreme Court overturned a Delaware Chancery Court decision that imposed a mandatory obligation on a target company to solicit alternative transactions for 30 days despite a prohibition against...more

Currency Conversion Concerns: New York Issues Guidance on Virtual Currencies

On December 5, 2014, the New York Department of Taxation and Finance (Department) released TSB-M-14(5)C, (7)I, (17)S. This (relatively short) bulletin sets forth the treatment of convertible virtual currency for sales,...more

U.S. Department of Commerce Announces Final Tariffs on Chinese and Taiwanese Solar Products

On December 17, 2014, the U.S. Department of Commerce (DOC) announced its final determinations in the antidumping duty (AD) and countervailing duty (CVD) investigations of crystalline silicon photovoltaic products (“solar...more

UK Targets Corporate Profits Of Multinational Enterprises With Sweeping Tax Changes

On December 3, the UK Government announced its intention to introduce a new “diverted profits tax” (DPT) to take effect on April 1, 2015. Draft legislation was published on December 10 and is now subject to a public...more

Congress Passes One-Year Extension of Business and Individual Tax Provisions

On December 16, 2014, the Senate voted 76-16 to pass H.R. 5771, the Tax Increase Prevention Act of 2014 (“TIPA”), which was passed by the House by a vote of 378-46 on December 3, 2014. TIPA would extend over fifty (50)...more

The UK’s New Diverted Profits Tax

The UK Treasury has published the draft legislation for the new Diverted Profits Tax (DPT), which it plans to introduce from 1 April 2015. This has been unofficially described as the “Google Tax”, and represents part of the...more

Hybrid Mismatches – UK Proposals for Implementing the BEPS Recommendations

The United Kingdom made its first substantive commitment arising out of the base erosion and profit shifting (BEPS) initiative on 3 December 2014, with the release of a consultation paper on implementing the agreed G20-...more

International Tax News - December 2014

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS - The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015. The government has published...more

2014 Year-End Tax Update

I. A LOOK BACK AT 2014 TAX MATTERS: A. Some Random Observations - ..1. This year’s update is brought to you by the letter “I,” as in “inversions.” ..2. Tired of waiting for Congress to address what they...more

The Financial Report - Volume 3, No. 22 • December 11, 2014 (Global)

Discussion and Analysis - Earlier this week, The Wall Street Journal published a special Journal Report entitled “CEO Council.” The tag line for the report ominously states: “At the annual meeting of The Wall Street...more

Diverted Profits Tax – First Thoughts

The UK Government intends to introduce a 25% “diverted profits tax” (DPT) from 1 April 2015. The tax is designed to catch the artificial erosion of the UK corporate tax base by multi-nationals that avoid establishing a...more

Via Libera Alla Voluntary Disclosure: Gli Aspetti Principali Della Disciplina In Attesa Della Pubblicazione In G.U.

E' in attesa di pubblicazione sulla Gazzetta Ufficiale il testo di legge approvato giovedì 4 dicembre dal Senato in materia di rientro dei capitali dall'estero (c.d. Voluntary Disclosure o Collaborazione Volontaria). Oltre...more

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