International Trade Business Organization Tax

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European M+A News, Winter 2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

Recent Revisions to Internal Revenue Code Affecting Alcohol Beverages

In December 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (PATH Act). The PATH Act amends several provisions of the Internal Revenue Code of 1986 (IRC) administered by the Alcohol...more

Focus on Tax Controversy and Litigation - New Partnership Audit Procedures May Dramatically Affect the Assessment and Collection...

In addition to the discussion of the new partnership audit rules, this month’s issue features articles regarding a recent district court decision in Ellis v. United States regarding the attorney-client privilege and work...more

European Commission Publishes Anti Tax Avoidance Package

On 28 January 2016, the European Commission published a draft Anti Tax Avoidance Package in order to ensure increased tax transparency and effective taxation within, and outside of, the EU. The package includes a proposed...more

Cross-Border Banking and Out-of-this-World Penalties - Dealing with the IRS when you have Foreign Bank Accounts

A United States citizen or resident that owns (or has signatory authority over) an account at a foreign bank with a value in excess of $10,000 annually must file a Report of Foreign Bank and Financial Account (or “FBAR”) with...more

Foreign Films Take a TRIP to France

Tax Rebate Changes - In 2016, France increased its efforts to attract foreign films by loosening language restrictions and increasing the amount of tax rebates available for films that are shot in France. In the past,...more

Federal Appellate Court Rules that Certain Foreign Currency Options Are Subject to the Section 1256 Mark-to-Market Regime

Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options (and also, possibly, to foreign currency...more

European Commission Proposes an Anti-Tax Avoidance Directive

The proposed Council Directive marks another, significant, though likely problematic, step towards tackling tax avoidance across Member States. Background - The European Commission (the Commission) has been moving...more

BEPS Action 7: how the OECD's proposals to redefine a PE could affect multinationals

The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions....more

PATH Act Brings FIRPTA Changes

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed December 18, 2015, introduces significant changes to the Foreign Investment in Real Property Tax Act (FIRPTA), particularly concerning REITs. ...more

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

Significant Changes to U.S. Taxation of REITs and Investments by Non-U.S. Investors in Real Property under the PATH Act

On December 18, 2015, President Obama signed into law an omnibus appropriations bill which included the Protecting Americans from Tax Hikes Act of 2015 (the "Act"). In addition to extending or making permanent a number of...more

New FIRPTA Reform Creates PATH to Potential Benefits for Existing REITs and Foreign Investors in the United States

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Among other changes, the PATH Act significantly modifies provisions of the Internal Revenue Code of...more

European Commission releases anti-tax-avoidance package – practical takeaways

The European Commission has released its highly anticipated anti-tax-avoidance (ATA) package. The package, released January 28, 2016, contains proposed rules and recommendations to avoid aggressive tax planning within...more

Focus on Tax Strategies & Developments - January 2016

Protecting Americans from Tax Hikes Act of 2015—the Year-End Legislation f/k/a Extenders - Just in time for Christmas, Congress passed, with bipartisan support, and the President signed, the “Protecting Americans from...more

Could 2016 Be the Year When Congress Finally Addresses Tax Reform?

Like Vladimir and Estragon waiting for Godot, Washington has been waiting for Congress to tackle tax reform. The reason for the lack of action is a fundamental disagreement between Democrats and Republicans over what reform...more

EU Anti-Tax Avoidance Directive Published: Implications For Corporate Taxpayers In Belgium

On 28 January 2016 the EC published the proposal for a so-called Anti-Tax Avoidance Directive. It applies to all taxpayers which are subject to corporate tax in an EU Member State, including corporate taxpayers without...more

NJ Senators Hold Press Conference on Combined Reporting

New Jersey Senators Lesniak (D), Greenstein (D), and Sarlo (D) held a press conference today concerning combined-reporting legislation that they are sponsoring....more

Singapore’s Income Tax (Amendment) Bill 2016

Upcoming changes to the Exchange of Information framework hints at future adoption of the Organisation for Economic Co-operation and Development’s Common Reporting Standards. The crux of Singapore’s Income Tax...more

New FIRPTA Changes Provide Significant Opportunities, But No Panacea for Encouraging Non-U.S. Investment in U.S. Real Estate

Under FIRPTA, a non-U.S. person’s gain from the sale of U.S. real property interests is treated as income that is effectively connected with a U.S. trade or business (“ECI”), and therefore, is subject to U.S. federal income...more

The Delaware Competes Act Signed Into Law

This week, Delaware Governor Jack Markell signed into law HB 235, otherwise known as the Delaware Competes Act of 2016. HB 235 was passed by the Delaware State House of Representatives on January 14, 2016 and the Delaware...more

IRS Publishes Guidance for RICs that Receive Foreign Tax Credit Refunds

IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more

Out-of-State Subsidiary Holding Company Cannot Be Forcibly Included in a Colorado Combined Return

A Denver District Court judge has held that the Colorado Department of Revenue cannot forcibly combine a corporation’s subsidiary, a holding company that derived its income solely from investments in foreign entities, in...more

Tax State Aid: The European Commission concludes Belgian ‘excess profit’ rulings illegal

On January 11 2016, the European Commission (the Commission) again used Tax State Aid arguments to combat tax planning by multinationals when it announced its final decision in the formal state aid investigation into the...more

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the PATH Act, Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...more

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