International Trade Securities Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.
News & Analysis as of

Much-Anticipated Section 871(m) Dividend Equivalent Guidance Provides Promised Transition Relief

The U.S. Internal Revenue Service (the “IRS”) has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend equivalent transactions described in section 871(m) of the U.S. Internal...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Central Bank launches ORION II platform to authorise all QIAIFs applications - All QIAIFs applications (including ICAVs) will be processed via the CBI’s ORION platform allowing consistency with other legal structures and...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

Globally Taxing Issues for Private Equity

Tax has, in recent months, become a frontpage issue with reaction to businesses not “paying their fair share” sitting alongside pressure on government finances and an uncertain political environment. In our view, the...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

Significant Change In CRA Policy Harms Canadian Investors In US LLPs And LLLPs

Earlier this year the Canada Revenue Agency (“CRA”) announced its new administrative position that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) formed under the laws of Delaware...more

Countries at a Glance: Ireland - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - Employee entitlement claims are becoming increasingly common. Employees frequently seek compensation for loss of...more

Countries at a Glance: India - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - There is a risk that benefits under a stock purchase plan could be viewed as a part of the employee's salary and...more

Countries at a Glance: Hong Kong - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - Employee rights to receive Plan benefits after termination are not restricted by law. However, as a precaution,...more

Countries at a Glance: France - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - To reduce the risk of potential claims from employees that they have entitlements under Plans, Plans should be...more

Countries at a Glance: United Kingdom - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - Appropriate language should be included in enrolment forms stating that the employee has no rights to compensation...more

Countries at a Glance: Italy - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - It is becoming more common for employees to claim they have entitlements under Plans. The risk of employee claims for...more

Countries at a Glance: China - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - The requirement that employers in China remunerate employees in cash only, rather than in negotiable securities, is...more

Countries at a Glance: Belgium - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - To reduce the risk of potential claims from employees that they have entitlements under a Plan, employees should...more

Countries at a Glance: Australia - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - Employees may have rights to additional vesting or other benefits under the Plan in cases of involuntary termination....more

Countries at a Glance: Germany - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - In order to reduce the risk of German employment law restrictions applying to purchase rights granted to German...more

Countries at a Glance: Canada - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - To reduce the risk of potential claims from employees that they have entitlements under a Plan, the Plan and related...more

Countries at a Glance: Brazil - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - To reduce the risk of potential claims from employees that they have entitlements under a Plan, employees should...more

Countries at a Glance: Israel - Employee Stock Purchase Plans

Employee Stock Purchase Plans - Labor Concerns - A claim for breach of contract could arise where a Plan is amended or discontinued. It is recommended that Plan provisions are drafted so as to preclude temporary...more

Countries at a Glance: Denmark - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - Employee stock purchase plans have not been expressly included in the Danish Stock Option Act (the "Act"). However,...more

Countries at a Glance: Netherlands - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - It is becoming more common for employees to claim they have entitlements under Plans. The risk of employee...more

Countries at a Glance: Singapore - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - Employees should acknowledge that the offer of purchase rights does not create a right or entitlement to further...more

Countries at a Glance: Mexico - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - It is becoming more common for employees to claim they have entitlements under Plans. Standard waiver and consent...more

Countries at a Glance: Taiwan - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - Employees should sign a written disclaimer acknowledging that the Plan is a discretionary benefit offered to...more

Countries at a Glance: Japan - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - It is becoming more common for employees to claim they have entitlements under Plans. The risk of employee claims for...more

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