International Trade Science, Computers & Technology Tax

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Sports, Media and Entertainment Intelligence - October 2014 (Global)

BROADCASTING - France: French legislation on evening advertising on public channels: should we expect another shift in policy? - The main French public service broadcaster, France Télévisions, is calling for lift of...more

VAT Alert: Cross-Border Supplies Of Services Made To VAT Grouped Branches: Skandia America Corp. (USA), filial Sverige (C-7/13)

For VAT purposes, a supply of services from the headquarters of a company to its branch is generally not subject to VAT. This is well-established, and was confirmed in the Court of Justice of the European Union (the "Court of...more

Lame Duck Preview

With the November elections looming, the House and Senate completed their work last week before departing Washington to campaign, leaving any remaining legislative work for the post-election lame duck session. The brief work...more

European Court of Justice: Services by US Corporation to EU Based Branch May Attract Extra VAT Costs

On September 17, 2014, the European Court of Justice (ECJ) rendered its judgment in high-profile case C-7/13 upon request for a preliminary ruling in the proceedings Skandia America Corp. (USA), filial Sverige vs....more

International Tax News - August 2014

UKRAINE: NEW ANTI-CRISIS TAX MEASURES - The Verkhovna Rada, Ukraine’s Supreme Council, has approved amendments to the country’s tax law. Among the changes are amendments affecting the corporate profit tax and excise...more

Brazil revises law on tax treatment of cross-border payments for data centers located abroad

Newly published Brazilian Interpretative Act (Ato Declaratório Interpretativo) N. 7/2014 expresses the Brazilian IRS’s view regarding the tax treatment applicable to cross-border payments for the use of data centers located...more

Tax update: Australian tax and GST treatment of bitcoin and other crypto-currencies

Earlier today the ATO released its long awaited public guidance on the Australian tax and GST treatment of bitcoin and other crypto-currencies. This guidance was originally scheduled to be released on 30 June 2014. It was...more

Cahiers de droit fiscal international: Ukraine Cross-border outsourcing - issues, strategies and solutions

Summary and conclusions - Ukraine is experiencing the fast development of outsourcing industry due primarily to IT outsourcing. This is supported by tax incentives introduced for the IT sector. Ukrainian tax...more

International Tax News - July 2014

BITCOIN FORGES AHEAD: 3 QUICK LOOKS - Bitcoin is a decentralized peer-to-peer payment system that exists virtually and is unlimited by the constraints of countries, government or time. In an age when business leaps...more

Stampeding for the Exits: Pharmaceutical Companies and the Recent Wave of Inversions

Actavis, Pfizer, Medtronic, Abbvie and Salix have all recently announced plans to merge with foreign competitors and reincorporate in the U.K. or Ireland – a strategy commonly known as an “inversion” (Pfizer’s merger plans...more

Doing Business in Canada: Investment Incentives

INVESTMENT INCENTIVES - Generally, Canadian companies are expected to be self-supporting, but for companies involved in export development, there are several types of investment incentive programs which are designed to...more

Congress Returns from July 4th Recess - What to Expect in the Coming Months

Although the 113th Congress continues to see a dearth of legislation seeing final approval, over the past six months, Congress has managed to finalize Fiscal Year 2014 appropriations; address the Sustainable Growth Rate...more

Intangible Services, Rights And Digital Content: Global VAT Guide

Welcome to DLA Piper’s Global VAT Guide: Cross Border Supplies of Intangible Services, Rights and Digital Content. As business grows more global, the challenge for in-house counsel and in-house VAT specialists is...more

Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 2014

The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more

Corporate Inversions Showing No Signs of Slowing Down

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or...more

Bitcoin Reportability and Taxation

June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more

Bitcoins Do Not Require FBAR Filing

I have been posting a lot of FBAR-related posts lately. Here’s one more. There has been a question whether owners of “bitcoins” and other virtual currencies that have non-U.S. aspects, are subject to annual reporting...more

Delhi High Court upholds Centrica ruling: employee secondment may trigger permanent establishment

Multinationals with operations in India should take note of the Delhi High Court’s recently decision in Centrica India Offshore Pvt Ltd., in which it upheld a ruling of the Authority for Advance Rulings that an employee...more

Regulation Of Bitcoin Around The World

Governments and tax authorities continue to develop their fiscal and tax positions relating Bitcoins. Many countries are releasing warnings about the risks associated with the use of Bitcoins, with some providing more...more

Inversion Transactions Likely to Continue and Expand into Other Markets and Industries

During recent months there has been a surge in cross-border M&A activity in which U.S. and non-U.S. companies combine in so-called inversion transactions. Examples of these transactions are Endo International’s acquisition of...more

Recent Changes In Tax Legislation (Ukraine)

The law of Ukraine ?1166-VII "On Prevention of the Financial Disaster and Creation of the Grounds for Economic Growth in Ukraine" was adopted by the parliament on 27.03.2014 and signed by acting president on 31.03.2014. As a...more

Tax Talk -- Volume 7, No. 1 -- April 2014

In This Issue: - FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs - No Rule Policy on MLPs - IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m) - Rev....more

IRS Says Bitcoin Isn’t Money

On March 25, 2014 the IRS issued Notice 2014-21, which describes how the IRS will interpret existing general tax principles to apply to transactions using “virtual currencies” such as Bitcoin. This Notice is the most recent...more

IRS: Bitcoin Not A Currency For Tax Purposes

As expected, the U.S. Internal Revenue Service has provided some guidance on the U.S. tax treatment of Bitcoin. In Notice 2014-21 (March 25, 2014), the IRS stated that Bitcoin is property and not currency for tax...more

Update: EU VAT on E-Commerce

There are a great variety of electronically provided services (“e-services”) and the respective market is rapidly growing. The general definition is that e-services are services which are delivered over the Internet or an...more

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