International Trade General Business Tax

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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

ITC Solicits Public Comments On MTB Petitions - 45-Day Comment Period Open Until February 24, 2017

The U.S. International Trade Commission (“ITC”) is now accepting public comments on Miscellaneous Tariff Bill (“MTB”) petitions for duty suspensions and reductions that timely were filed with the agency by December 12, 2016,...more

HMRC Publishes Guidance on the Tax Treatment of Clawback of Remuneration in the UK

Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...more

TTB Changes Under the Fall Edition of the Unified Agenda

On December 23rd, 2016 the federal government published its Fall edition of the “Unified Agenda” – a bi-annual compilation of all ongoing federal rulemaking projects. Attached is a copy of the TTB detail from this latest...more

Some Tax Law Changes That Take Effect in 2017

No new tax legislation has come forth yet, but per tax laws passed in prior years, some changes in the law will occur in 2017. Chief among them...more

Amendment Protocol to the India-Singapore Tax Treaty Inked

Capital gains on alienation of shares to be taxable by India. The India-Mauritius tax treaty was amended by way of a protocol signed by the two countries on May 10, 2016—marking a landmark shift in India’s taxation...more

India Amends Capital Gains Tax Treaty With Singapore

The Government of India amended its double taxation avoidance agreement (DTAA) with Singapore on December 30, 2016. The amendment allows the Government of India to levy source-based capital gains taxes on foreign direct...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

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

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

U.S. Antiboycott Compliance: New Federal List Published

Companies doing business in the Middle East take note: The Treasury Department recently published its quarterly list of countries that currently require participation or cooperation with an international boycott, such as the...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

India and Cyprus Enter into New Tax Treaty

On November 18, India and Cyprus signed a revised agreement for the avoidance of double taxation and prevention of fiscal evasion. Per a November 18 press release issued by the Indian government, the revised agreement...more

Trump Administration's Tax Reform Likely

Donald J. Trump defied the polls and much of the national media to win the US presidential election on November 8, 2016. President-elect Trump will be sworn in and will take office as the 45th president of the United States...more

European Commission proposes simplified VAT rules for e-commerce supplies

On 1 December 2016, the European Commission unveiled plans to simplify the VAT rules for cross-border online sales (e-commerce). The Commission's proposal will make it easier for online businesses to access markets in (other)...more

OCAC Publishes Report on Voluntary Disclosure Program

The Offshore Compliance Advisory Committee (OCAC) has published its report on the CRA’s Voluntary Disclosure Program, the first of several anticipated OCAC reports in furtherance of the OCAC’s mandate to provide advice to the...more

Tax Truths: Volume 1, No. 2 – December 2016

AN ANALYSIS OF TAX LAW PROPOSALS OF THE PRESIDENT-ELECT AND THE HOUSE - President-elect Trump made tax reform a highlight of his campaign, calling for fewer tax brackets, lower individual rates, and reduced corporate tax...more

1,000 Miscellaneous Tariff Bill Petitions Filed And Counting: Filing Window Closes at 5:15 p.m. on December 12

More than 1,000 petitions seeking temporary duty suspensions and reductions pursuant to the American Manufacturing Competitiveness Act of 2016 (the Act) have been filed with the U.S. International Trade Commission (ITC). As...more

UK Autumn Statement 2016

This was Chancellor Phillip Hammond's first (and last) Autumn Statement. From Autumn 2017, there will be an Autumn Budget for the coming year, which will enable greater scrutiny of complex tax provisions, followed by a Spring...more

The Chancellor’s Autumn Statement

It’s that time of the quarter again and Chancellor Philip Hammond’s first (and last) Autumn Statement. It’s also the first Statement ‘post-Brexit’. The focus of the Statement has, as predicted, been on austerity versus...more

Development of Russian court practice on tax implications when dividends are paid to foreign companies (application of the...

On 13 October 2016 the Commercial Court of Kemerovo Region delivered a judgement in case No. ?27-20527/2015 (the “Decision”) under the claim of Krasnobrodsky Yuzhny Limited Liability Company (the “Company”)....more

McDermott International Legal Highlights November 2016

The New World of Global Tax Planning: a Checklist for Success - As all multinationals (MNEs) are discovering, domestic implementation of the recommendations set out in the base erosion and profit shifting (BEPS) final...more

Trump Risk Factors Begin to Appear in SEC Documents

Risk factors related to uncertainties resulting from possible policies that may be implemented by President-elect Trump have begun to appear in SEC filings...more

¿Podría el Presidente Trump sacar a los Estados Unidos del TLCAN? Preguntas frecuentes básicas.

Durante su campaña para presidente, el Presidente-Electo Trump prometió repetidamente renegociar el TLCAN e imponer un arancel del 35 por ciento sobre las importaciones procedentes de México y un arancel aun mayor a las...more

Advance pricing agreements: a new era

There has been a significant amount of negative press recently concerning tax rulings and advance pricing agreements (APAs); negativity that has been fuelled by the European Commission's state aid investigations, Lux leaks...more

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