International Trade Administrative Agency Tax

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Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

BSI Account Holders Now Face 50 Percent Penalty On All Undisclosed Offshore Accounts

On Monday, March 30, 2015, the Department of Justice (the "Department") announced its first settlement under the Swiss Bank Program, potentially exposing thousands of U.S. taxpayers to a steep 50 percent penalty for failure...more

BSI Is First Bank to Reach Resolution in DOJ’s Program for Swiss Banks

BSI of Lugano, Switzerland, became the first bank to earn a non-prosecution agreement under the U.S. DOJ’s Program for Swiss Banks, paying a penalty of $211 million. First announced on August 29, 2013, the program offered...more

Luxleaks - Challenging the challenges to tax rulings in the EU

The European Commission's recent state aid crusade against so-called sweet deals in the form of tax rulings may have unwelcome consequences never contemplated by the Commission....more

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

EU Passes New Council Directive to Implement “EU-FATCA" - The Council Directive passed by the EU on 1 December 2014 implements the OECD’s Common Reporting Standard (CRS) in Europe. The Directive has to be implemented...more

Canada makes Changes to its Customs Administrative Monetary Penalty System

On January 20, 2015, the Canada Border Services Agency (CBSA) issued revisions to its Administrative Monetary Penalty System (AMPS), found in Memorandum D22-1-1 Administrative Monetary Penalty System....more

"Challenging the IRS Anti-Inversion Notice: A Hollow Threat"

On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations aimed at blunting certain of the benefits from so-called inversion...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

Fiscal state aid: atomic alarm!

On 5 November 2014, a group of investigative journalists ("ICLG") placed approximately 540 rulings granted by the Luxembourg tax administration to some 340 companies active in a large number of industries (energy, financing,...more

Corporate tax exemption for U.S. investment funds investing in Poland Based on the ECJ C-190/12 case

On 10 April 2014, the European Court of Justice ("ECJ") issued a judgment in case C-190/12 concerning the authority of Poland to grant corporate income tax ("CIT") exemption to investment funds depending on where their...more

Administrative and criminal violations involving the same fact: the recent positions of the European Court of Human Rights and of...

The European Court of Human Rights takes a stand on the ne bis in idem principle intervening on the relationship between administrative and criminal violations involving identical facts. Two recent decisions give interesting...more

Taxpayer Wins New York Bank Tax Case: Division of Tax Appeals Determines that Department Violated its Own Published Guidance

In a recent decision, the New York State Division of Tax Appeals soundly rejected a determination by the New York State Department of Taxation and Finance (the "Department") that it could treat a banking corporation’s...more

The Plight of Billionaires Looking For New Havens to Shield Assets

The Plight of Billionaires Looking For New Havens to Shield Assets by James F. McDonough, Jr. on July 30, 2013 In a recent article in Wealth Management, the author David de Jong and Robert Lafranco describe the...more

How Tobin Tax and certain regulatory duties affect Block Trades in Italy

Italian Law No. 228 dated December 24, 2012, which approved the 2013 budget, contemplates, among others, a new tax applicable to certain financial transactions (the “Tobin Tax”). The Tobin Tax will apply to transactions,...more

CRA Releases New APA Report

This is the eleventh year in which the CRA has issued such a report, which is generally intended to enhance taxpayer awareness of the APA program and to describe (i) current operational status, (ii) relevant changes, and...more

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

FinCEN Extends FBAR Filing Deadline

On December 26, FinCEN issued Notice 2012-2 to extend the deadline for certain filers to submit the Report of Foreign Bank and Financial Accounts (FBAR). FinCEN has extended this deadline several times in the past and the...more

UK Tax Law Changes May Affect Fund Industry

Recently proposed changes in UK law could affect private investment funds that operate or have partners, employees or investments in the UK. Many of the proposed changes are included in the draft Finance Bill 2013, which was...more

FinCEN Announces Third Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts. ...more

FBAR-The New Marriage Penalty

For those U.S. taxpayers who are married to non-residents there is a new form of marriage penalty if the spouses filed joint returns. To be eligible to file joint returns an election must be made with the first joint return...more

Bureau Proposes Further Revisions to Remittance Transfer Rules

On December 31, 2012, the Consumer Financial Protection Bureau (“Bureau”) published in the Federal Register revisions (“Proposal”) to rules on international remittance transfers that the agency published in February 2012 and...more

Financial Services – Update on UK and European Regulatory Developments

This update summarises current regulatory developments impacting the asset management sector in the UK and throughout the European Union. In this issue: - Part A – Regulation of Financial Markets - Part B –...more

FATCA – 2013 and Beyond

Tax lawyer Stuart Schabes co-presented “FATCA – 2013 and Beyond” at The Perfect Storm: US Tax Legislation and IRS Compliance 2013, a program hosted by Philip Stein & Associates and ERM. The discussion...more

Foreign Taxpayers Can Benefit Despite Proposed Regulations

Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more

EU Customs Practice Group - November 2012

In This Issue: * EU CUSTOMS POLICY - MCC/UCC recast proposal * TARIFFS - Update on duty suspensions/tariff quotas - EU preferences adopted for Pakistan - FTA update * CLASSIFICATION -...more

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