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Changes in tax and customs legislation: novelties in the appeals procedure and certain administrative matters

From 1 January 2017 numerous changes to the tax and customs legislation of the Republic of Kazakhstan has become effective. The majority of these changes were introduced by the Law of the Republic of Kazakhstan dated 30...more

Kyiv Tax Newsletter (Ukrainian)

Subsistence minimum and minimum wage - On 21 December 2016 the Parliament of Ukraine adopted the Law “On the State Budget of Ukraine for 2017” No.1801-VIII (hereinafter, "the Law on State Budget"). The Law on State...more

New IRS Reporting Rule Could Bite Unwary Foreign Investors

There are two main sources of reporting requirements for foreign investors in the United States — the Internal Revenue Service and the Bureau of Economic Analysis. The IRS recently upped its game by requiring reports from...more

Kyiv Tax Newsletter

Subsistence minimum and minimum wage - On 21 December 2016 the Parliament of Ukraine adopted the Law “On the State Budget of Ukraine for 2017” No.1801-VIII (hereinafter, "the Law on State Budget"). The Law on State...more

Complying with legal requirements on controlled foreign corporations

Dentons’ Russia Tax practice would like to remind readers that starting in 2017 individuals and legal entities that are deemed Russian tax residents must annually file notices about foreign entities and unincorporated...more

Worries about NAFTA Take Back Seat to Potential “Border Adjustment Tax”: Law Firm of Miller Canfield

Companies importing goods into the U.S. should pay very close attention to the serious discussions now taking place in Washington, D.C. regarding a major restructuring of the U.S. corporate income tax scheme to include a...more

The favourable tax regime of new Italian residents

The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The...more

Client Alert on the Law On Non Cash Settlements

On 16 December 2016 the President of the Republic of Azerbaijan signed the law On Non-Cash Settlements (the “Law”). Below is a general summary of the Law...more

Real Estate Advisory: Canada Revenue Agency Announces Changes to Treatment of U.S. LLLPs and LLPs

The Canada Revenue Agency (CRA) recently announced a change in the treatment of U.S. limited liability limited partnerships and U.S. limited liability partnerships (the “Entity Types”) for Canadian tax purposes. For Canadian...more

Tax Reform in the New Administration

The upcoming change in administration, combined with retained Republican control of both houses of Congress, is expected to result in significant changes in the federal income tax system, on both the domestic and...more

New Amendments to the Tax Code

On 16 December 2016 the President of the Republic of Azerbaijan signed a law amending the Tax Code (the “Amendment Law”). These are the long-awaited amendments whose adoption was expected after the President signed on 4...more

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more

Transfer pricing rules to change in Ukraine from 2017

On December 21, 2016, the Verkhovna Rada of Ukraine approved in the second reading the Draft Law "On Amending the Tax Code of Ukraine (on the Improvement of Investment Climate in Ukraine )" No. 5368. The law has been sent to...more

German tax law changes and their impact on multinationals

On 2 December 2016, the Act for the implementation of the amendments of the EU Administrative Cooperation Directive and of further measures to counter base erosion and profit shifting - having been approved by the Lower House...more

"'Failure to Prevent': The Implications for Global Financial Institutions"

The U.K. government is set to introduce a new corporate criminal offence, based on the strict liability of the entity in question. It almost certainly will come into force in 2017, once the Criminal Finances Bill (Bill) is...more

World Bank publishes Transfer Pricing Handbook for developing countries

On 23 December 2016, the World Bank Group published a transfer pricing handbook "Transfer Pricing and Developing Economies: A Handbook for Policy Makers and Practitioners". The Handbook, which comprises eight chapters...more

Financial Services Quarterly Report - Fourth Quarter 2016: The Impact of New U.S. Partnership Audit Rules on Investment...

The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986, as amended (Code), governing partnership audit proceedings. The new provisions are designed to simplify the ability of...more

New Reporting Requirements for U.S. Disregarded Entities Owned by Foreign Persons

Code § 6038A imposes reporting and recordkeeping requirements on domestic corporations that are at least 25% foreign-owned. They are required to file an annual return on Form 5472 with respect to each related party with which...more

Luxembourg Parliament Adopts 2017 Tax Reform Introducing New Tax Measures for Individuals and Corporates

The Luxembourg Parliament adopted the 2017 tax reform (parliamentary document n°7020) on 14 December 2016 which introduces new tax measures affecting both individual and corporate taxpayers. The publication of the law is...more

"The New UK Corporate Offence of 'Failure to Prevent the Facilitation of Tax Evasion': Implications for Fund Managers and...

The U.K. government expands its crackdown on tax evaders and the persons who assist them, by targeting businesses who fail to prevent tax evasion....more

Country by Country: Luxembourg introduces law on country-by-country reporting

On the 13th of December, the Luxembourg parliament voted in favour of a law on country-by-country reporting (CbCR). The conditions for a Luxembourg tax resident company to be subject to CbCR are the following...more

IRS Finalizes Regulations That Limit Nonrecognition On Certain Outbound Section 367(a) Transfers & Other Outbound Rule Changes

U.S. persons transferring appreciated property to foreign corporations may be eligible for nonrecognition of gain using Section 351 or the corporate reorganization provisions. However, Code §367(a) and its regulations provide...more

Tax break for infrastructure projects

To implement the G20/OECD base erosion and profit shifting project, the 2016 Budget announced measures limiting tax deductions that companies can claim from their interest expenses (read DLA Piper's earlier client alert on...more

Country by Country: Spain

The new Spanish Corporate Income tax Regulations were approved on 11 July 2015 through the Royal Decree 634/2015, which complement the provisions included in the Spanish Corporate Income Tax Law (Law 27/2014) that entered in...more

Country by Country: United Kingdom

Introduction - The UK CbC reporting regulations ("The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016") were made on 26 February 2016....more

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