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General Business Tax International Trade

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

AFRICA - A Legal Guide for Business Investment and Expansion: Tunisia

1. What role does the government of Tunisia play in approving and regulating foreign direct investment? The Tunisian government places a priority on attracting foreign direct investment. The Tunisian government...more

Ireland's Revenue releases guidelines on requesting Mutual Agreement Procedure assistance

by DLA Piper on

Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tanzania

1 .What role does the government of the United Republic of Tanzania play in approving and regulating foreign direct investment? The government plays an active role in approving and regulating foreign direct investment....more

Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest

by McDermott Will & Emery on

In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more

Cumplimiento Fiscal Internacional

by Foodman CPAs & Advisors on

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Gain Realized By Non-Resident Foreign Partner Upon The Sale Of Its Interest In A U.S. Partnership Is Not U.S.-Source Income Unless...

by Roetzel & Andress on

In Grecian Magnesite Mining, Industrial & Shipping Co., SA, v. Commissioner of Internal Revenue (filed on July 13, 2017), the United States Tax Court overturned Revenue Ruling 91-32 (which had been relied on since 1991) and...more

AFRICA - A Legal Guide for Business Investment and Expansion: Nigeria

1 .What role does the government of nigeria play in approving and regulating foreign direct investment? Due to the economic benefits that accompany Foreign Direct Investment (FDI), the Nigerian government strives to...more

Can Foreign Partners Now Exit Partnerships Tax Free?

by Bracewell LLP on

In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more

Sale of U.S. Operating Partnerships by Non-U.S. Persons May Not Generate ECI—U.S. Tax Court Declines to Follow Revenue Ruling...

by K&L Gates LLP on

In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service (“IRS”), articulated in Revenue Ruling 91-32, that a non-U.S. partner’s gain or loss from...more

Eaton v. IRS: Tax Court determines IRS abused its discretion in cancelling two APAs

by DLA Piper on

The Tax Court in Eaton Corporation and Subsidiaries v. Commissioner, T.C. Memo, 2017-147 determined that the IRS abused its discretion in cancelling two unilateral advanced pricing agreements (APAs) covering the transfer of...more

AFRICA - A Legal Guide for Business Investment and Expansion: Ghana

1. What role does the government of Ghana play in approving and regulating foreign direct investment? The Government of Ghana continues to promote foreign direct investment in Ghana. In 2013, the Ghana Investment Promotion...more

Forging ahead: US M&A H1 2017: Forging ahead: H1 in review

by White & Case LLP on

Expectations of another bumper year for US M&A failed to materialize in the first half of 2017, as total deal volume fell below 2016 levels. In the first six months of 2017, there were 2,413 deals, an 8 percent drop from...more

The Malta Pension Plan – A Supercharged, Cross-Border Roth IRA

by Bilzin Sumberg on

In the cross border setting, two of the principal goals in international tax planning are (i) deferral of income earned offshore and (ii) the tax efficient repatriation of foreign profits at low or zero tax rates in the...more

AFRICA - A Legal Guide for Business Investment and Expansion: Egypt

1 .What role does the government of Egypt play in approving and regulating foreign direct investment? Egypt has traditionally been a leader in the Arab world in the political, cultural, and economic spheres. Due to recent...more

U.S Tax Court Bounces Rev. Rul. 91-32: Sales of Partnership Interests by Foreign Partners May Not be Subject to U.S. Tax

by Dickinson Wright on

The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more

Tax Planning for Investment Into the United States Through Hybrid Entities - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more

AFRICA - A Legal Guide for Business Investment and Expansion: Angola

1. What role does the government of Angola play in approving and regulating foreign direct investment? Foreign direct investment is a highly-regulated sector in Angola. In August 2015, the Angolan Government enacted Law...more

Big Tax Court Win for Foreign Investors in U.S. Partnerships

by Alston & Bird on

A foreign investor, not engaged in a U.S. trade or business, can sell stock in a U.S. corporation without fear of U.S. tax liability (with the notable exception of stock in certain U.S. corporations heavily invested in U.S....more

Did you know that Form 8938 filing obligations apply to Specified Domestic Entities?

by Foodman CPAs & Advisors on

A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified...more

Renewal of U.S. FATCA Registration for Certain Investment Funds by Monday, July 31, 2017

Certain non-U.S. investment funds, including Bermuda funds, which qualify as foreign financial institutions (FFI), must enter into a legal agreement (“FFI agreement”) with the U.S. Internal Revenue Service (IRS) to be treated...more

Corporate Inversions

by Kelley Drye & Warren LLP on

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

Impact of the Multilateral Instrument on U.S. Taxpayers

by Alston & Bird on

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all...more

IRS Identifies 8 Burdensome Regulations for Reform

Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden that the...more

Trade & Manufacturing Alert - July 2017

by King & Spalding on

Ambassador Lighthizer Visits Congress To Discuss The President’s Trade Policy Agenda - In June, the Senate Finance Committee and Ways and Means Committee of the House of Representatives held hearings on the new...more

Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

by Foodman CPAs & Advisors on

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations...more

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