General Business Tax International Trade

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Tax Implications For Real Property Leasing

Reforms to China’s value-added tax raise issues that landlords should consider when designing leasing structures and negotiating rental terms. On May 1, 2016, China’s value-added tax (VAT) replaced the business tax in...more

Digesting the €13 Billion Apple-EU Tax Ruling

King & Spalding experts assess what international businesses need to be aware of following the EC's ruling on State Aid in the Apple case - Partners in King & Spalding’s tax department have shared their perspectives and...more

Structured Thoughts: News for the financial services community, Volume 7, Issue 9

Updating Unregistered Structured Note Programs: How Frequently? - For some types of securities offering programs, we have “black letter law” that instructs issuers how frequently the program documentation should be...more

New Countries Eligible for Italy's White List

In the Official Gazette No. 195 of 22 August 2016, the Italian Government published the Ministerial Decree of 9 August 2016 (the "Decree") that amended the list of countries and territories "allowing an adequate exchange of...more

Customer Due Diligence in the Post-Panama Papers Era

Sometimes it takes a scandal to advance a policy or law enforcement cause. The Panama Papers scandal has given new life to financial regulators around the world who seek to impose customer due diligence requirements on banks...more

EU tax ruling levies €13 billion state aid penalty on Apple

On 30 August 2016, Ireland was ordered by the EC to recover up to €13 billion from Apple on the basis that tax arrangements implemented between Apple and Ireland, originally in 1991, amounted to the provision of unlawful tax...more

The sukuk experience in Turkey

Turkey's government is determined to make Istanbul a financial hub for Islamic finance, regionally and globally. With a GDP of US$733.6 billion in 2015 according to the IMF, Turkey is the 18th largest economy in the world,...more

Battle Heats Up Over Who Can Regulate Tax on International Companies

In a decision that again pits the United States against the European Union in that ongoing battle over which entity can primarily tax international business, Margrethe Vestager, the European Union commissioner for...more

Jumeirah Lake Towers Freezone

Jumeirah Lakes Towers (JLTFZ) is a 200-hectare, mixed-use waterfront development which offers commercial, residential and retail property for sale and lease. The Freezone was established in 2002 and now has over 3,800...more

Cancellation of CFC Loans to US Shareholders – Should the Service Get a Second Bite at the Apple?

The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general rule, such as where a taxpayer files a false return or omits more than 25...more

Indian Government Approves New India-Cyprus Tax Treaty

The Indian government approved a new India-Cyprus tax treaty on August 24, 2016 that will allow the Indian government to tax capital gains on investments routed through Cyprus. This is part of a continuing campaign by the...more

WTO Panel Report: Russia - Tariff Treatment

A WTO Panel has ruled that the Russian Federation has violated its WTO obligations by imposing duties on certain EU goods in excess of its committed ("bound") rates, in breach of Article II of the General Agreement on Tariffs...more

IRS Publishes List of Countries Requiring Cooperation with an International Boycott

Non-listed countries can also present compliance issues under both IRS and Commerce Department Requirements. On August 5, the US Department of the Treasury’s Internal Revenue Service (IRS) published in the Federal...more

Focus on Tax Strategies & Developments - August 2016

Brexit: The Consequences for International Tax Planning - Just over a month has now passed since the referendum in which the United Kingdom voted narrowly to leave the European Union: an event which some have...more

Dubai Airport Freezone Authority

Dubai Airport Freezone (DAFZA) is one of the region’s fastest growing Freezones. Established in 1996, DAFZA is home to over 1,450 companies, covering a range of key industry sectors, including aviation, freight & logistics,...more

No Obligation to File Inaccurate Return to Avoid Failure to File Penalty

A partnership was a partner in a Cayman Islands partnership - that investment made up most of its assets. The Cayman Islands partnership did not file a Form 1065 income tax return and did not give a Form K-1 to the taxpayer...more

AccountingToday Article Provides Tax Primer: “Global Commerce 101”

Owners of small to mid-size U.S. businesses are finding the world is a smaller place, which can be very good for business. However, the opportunities of the international marketplace come with additional responsibilities,...more

New Law on Tax and Social Security Premium Amnesty in Turkey

On August 3, 2016, Turkey passed a detailed new law entitled "Statutory Proposal on Restructuring of Certain Receivables" (the "Law") which offers taxpayers a broad amnesty for most types of unpaid taxes and for unpaid social...more

Will the Panama Papers Lead to Criminal Charges Against U.S. Taxpayers?

The International Consortium of Investigative Journalists (ICIJ), collaborating with German newspaper Süddeutsche Zeitung, in spring 2016 began leaking approximately 11 million internal documents obtained without permission...more

CRA Provides OTIP Update

The CRA’s Offshore Tax Informant Program (OTIP) was launched in January 2014. From the CRA’s webpage describing the program: Launched as part of the Canada Revenue Agency’s (CRA) efforts to fight international tax...more

Liberia and Afghanistan Officially Join the World Trade Organization

In July, the Republic of Liberia (Liberia) and the Islamic Republic of Afghanistan (Afghanistan) officially joined the World Trade Organization (WTO). Liberia and Afghanistan are the 163rd and 164th countries, respectively,...more

New VAT regime for e-services

On 1 January 2017 the special VAT regime for "electronically supplied services" ("e-services") comes into effect, as introduced by Federal Law No. 244-FZ dated 3 July 2016....more

Brexit: Overview of Potential Impact on Derivatives

The process of Brexit will take many years, and the implications for our clients’ businesses will unfold over time. Our MoFo Brexit Task Force is coordinating Brexit-related legal analysis across all of our offices, and...more

IRS Wins Debt vs. Equity Case

A frequent area of dispute between taxpayers and the IRS is whether an indebtedness obligation should be treated as debt, or an equity investment, for income tax purposes. Taxpayers often seek debt treatment to obtain...more

ECJ Ruling Opens Door To Withholding Tax Refunds

The European Court of Justice (ECJ), in the case of Brisal, has determined on 13 July 2016 that national law which prohibits a non-resident taxpayer from deducting financing/operating costs from interest withholding tax...more

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