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General Business International Trade Tax

Read need-to-know updates, commentary, and analysis on General Business issues written by leading professionals.

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

The Cannabis Act: An overview

by Dentons on

On April 13, 2017, Canada’s Liberal government introduced Bill C-45, the Cannabis Act (the “Act”). The tabled legislation provides federal guidelines for legal access to cannabis for non-medical purposes and establishes...more

Tax Court Déjà Vu – IRS Tried, and Failed, to Overturn Veritas

by Alston & Bird on

In a recent decision (Amazon Inc. v. Commissioner, March 23, 2017), the Tax Court handed the IRS an unsurprising loss when it attempted to relitigate many of the same issues it unsuccessfully raised before the Tax Court in...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

by Dechert LLP on

CSSF Press Release 17/06 Dated 13 February 2017 - The CSSF confirmed that it follows ESMA on its opinion in relation to the requirements for UCITS share classes....more

Tax Considerations For The Closely-Held Foreign Investor In U.S. Real Property – Part II

by Farrell Fritz, P.C. on

Aside from planning for the taxation of U.S.-sourced rental income, the foreigner must plan for the disposition of the USRP pursuant to a sale. The taxation of gain realized by a foreigner on the sale of an interest in...more

Prepared for the Border Adjustment Tax? A U.S. and Global Perspective

by K&L Gates LLP on

K&L Gates' Global Tax Group has been monitoring the potential impact of the Border Adjustment Tax (BAT) across a number of jurisdictions. In our 14 February 2017 update, we commented that issues regarding the legality of...more

Singapore Strengthens Tax Cooperation with Other Countries

by Morgan Lewis on

One year after the ratification of the OECD Convention on Mutual Administrative Assistance in Tax Matters, Singapore has entered into automatic exchange of information agreements....more

Russia clarifies procedures for Bilateral Advance Pricing Agreements

by DLA Piper on

On 17 March 2017 the Ministry of Finance of Russia (MoF) posted a draft order on the procedure for conclusion of bilateral advance pricing agreements (APAs) with the authorised bodies of foreign states. This draft order fills...more

Brussels Regulatory Brief: April

by K&L Gates LLP on

On 13 March 2017, it was announced that a United States (“U.S.”) chipmaker will acquire an autonomous vehicle technology company based in Israel for approximately USD 15.3 billion. This transaction may provide an interesting...more

Belgium: IP tax incentive - implementing the nexus approach and broadening the scope of application

by DLA Piper on

In 2007, Belgium introduced a patent income deduction (PID) for Belgian companies (and permanent establishments of foreign companies) that derive income from or by means of patents and supplementary protection certificates....more

The Australian Government significantly expands ATO powers to fight multinational tax avoidance: Legislation introduced for 40 per...

by DLA Piper on

The Australian Government introduced legislation (DPT legislation) into Parliament on 9 February 2017 to implement a further component (second limb) of the United Kingdom–style diverted profits tax (DPT), with effect from 1...more

Taxing the Digital Economy: Impending changes to GST in Singapore

by Dentons on

Should digital downloads, streaming services and online purchases from foreign entities be subject to goods and services tax (GST) in Singapore? How about off-premise cloud computing?...more

Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again

by Jones Day on

On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary... ...more

FDIC Chairman: A “Culture of Compliance” Begins at the Top

by Ballard Spahr LLP on

In his remarks during last week’s launch of Case Western Reserve School of Law’s Financial Integrity Institute, FDIC Chairman Martin J. Gruenberg spoke on the historical context of today’s BSA/AML regulatory framework and the...more

Saudi Arabia Update - March 2017

by Dentons on

Legal developments - The Kingdom continues its move towards e-government services - Ministry of Municipal and Rural Affairs considers issuing temporary licenses online for multiple activities - The Ministry of...more

HMRC publishes responses to the consultation on Partnership taxation

by Goodwin on

The result of the HM Revenue & Custom's consultation on UK partnership taxation was released on 20 March, this is important for both fund partnerships and fund managers structured as LLPs which file UK tax returns. Although...more

Senegal's New Mining Code

by DLA Piper on

Senegal has officially introduced its new mining code, which has been a work in progress since 2012 when proposals were first made to revise the former mining code introduced in 2003. In recognising the potential that the...more

Tightening the Tax Screws on International IP Structures

by Carlton Fields on

For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more

Important New Business Tax Proposals for U.S. Tax System

by Hodgson Russ LLP on

During the past few months, there has been considerable speculation over potential changes to the U.S. tax system that could have an impact on international businesses. At this stage, the discussions are preliminary and the...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

The U.S. Tax Reform and the Energy Sector

by Hogan Lovells on

President Donald Trump and Republican Congressional leaders have promised a major reform to the U.S. tax code in 2017. This reform, if anything close to these promises, will have significant implications for the energy...more

House Blueprint’s Destination-Based Cash Flow Tax: A Primer

by Shearman & Sterling LLP on

The election of Donald Trump in November has substantially increased the likelihood of major tax reform in the near future. While it is uncertain what shape such reform will take, there has been renewed interest in the...more

Funds Bulletin - February 2017

by Hogan Lovells on

Funds Bulletin (a monthly round-up of topical legal, regulatory and tax issues affecting the fund industry). Features our summary of the FSCP's position paper on the impact of Brexit on financial services consumers, as well...more

TIC Form SHC Deadline Approaching to Report U.S. Ownership of Foreign Securities

The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC) data reporting system. Form SHC is the mandatory five-year...more

Key Takeaways: Prospects for US Business Tax Reform — What You Need to Know

On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more

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