International Trade Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.
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Countries at a Glance 2016: Spain - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - Employers should distribute a hard-copy disclaimer which acknowledges the employees' receipt of the Plan documents as...more

Using corporate structures to own UK residential property – a dead end?

Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more

Proposed Regs May Limit US Estate Plan

On August 2, 2016, the US Treasury issued long-awaited pro- posed regulations under Code section 2704 that make comprehensive and very significant changes to the valuation of interests in many family-controlled entities for...more

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

Luxembourg VAT authorities: Circular on VAT Treatment of Director Services - The Luxembourg VAT authorities published Circular n° 781 on 30 September 2016 regarding the VAT treatment of director services and a...more

Brexit: Hard Landing/Soft Landing or Down the Rabbit Hole: What’s Ahead?

This is the third in an ongoing series of blog posts by Foley & Lardner LLP on the implications of the June 23, 2016 referendum decision in the United Kingdom (“UK”) to exit the European Union (“EU”)...more

Proposed Amendments to UK Proceeds of Crime and Terrorism Legislation 

A Bill was introduced in the UK Parliament proposing amendments to the Proceeds of Crime Act 2002 and Terrorism Act 2000. The Bill forms part of the UK Government’s Action Plan to counter money laundering and the funding of...more

Miscellaneous Tariff Bill Petition Process Goes Live - Potential for up to $500,000 in duty relief per product

The U.S. International Trade Commission (“ITC”) has begun accepting petitions seeking temporary duty suspensions and reductions pursuant to the American Manufacturing Competitiveness Act of 2016 (“the Act”). The Act...more

U.S. Taxes and the 2016 Election: More of the Same on the International Front

When it comes to proposed tax reform, the devil is always in the details. Business Taxes - On the business tax front, Mr. Trump’s proposal lowers the corporate tax rate to 15% (from a maximum 35%), while Mrs....more

Inheritance Tax Reform passed – Germany misses chance to tame Tax-Bureaucracy for Family Owned Businesses

Bryan Cave’s Tax law expert Stefan Skulesch: “Last minute solution with flaws will continue to impede company successions in Germany” - On 14 October 2016 the Bundesrat (the upper house of the German parliament) has...more

De-Risking 101

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Report to G20 on Beneficial Ownership

The Financial Action Task Force published a report to the G20 Finance Ministers and Central Bank Governors updating them on the steps being taken by the FATF on implementation of international standards on transparency and...more

EU court eases formal invoice requirements for input tax deduction

According to two milestone decisions in September 2016 of the EU Court of Justice (Senatex, case C-518/14 and Barlis 06, case C-516/14) formal invoice requirements for input tax deduction have been eased. Taxpayers should...more

U.S.-India Newsletter - Vol. 2016, Issue 3

Summer 2016 was a season of change. In Europe, we saw the "Brexit," with the United Kingdom voting to withdraw from the European Union. The June referendum sent shockwaves through the business and finance communities and...more

Recent Changes to the India-Mauritius Tax Treaty: What Does This Mean for American Investors?

The amendments may cause some uncertainty and anxiety for U.S. investors as they consider how these changes will impact business, income, profitability and the benefits or drawbacks of investing in India through Mauritius....more

UAE Freezones: Ras Al Khaimah

Ras Al Khaimah Free Trade Zone (RAK FTZ) is a free zone based in RAK and was established in 2001. The free zone has over 5,000 companies as its members cover various fields and economic activities....more

Luxembourg VAT Authorities issue Circular n°7891 on VAT treatment of directors’ fees.

On September 30, 2016, the VAT authorities confirmed that VAT shall apply to directors’ fees. From a VAT standpoint, "any person who carries out in an independent and usual manner any economic activity, whatever the...more

The Luxembourg indirect tax administration confirms the VAT treatment of director fees

On 30 September 2016, the Luxembourg indirect tax administration (LTA) issued a circular n°781 confirming that director fees are subject to VAT (the Circular). As reported in our previous e-alert on this matter circulated in...more

US Citizenship Renunciation Procedures in Canada

The US constitution protects a US citizen from automatic loss of citizenship. Expatriation can only occur through the voluntary, intentional commission of an expatriating act that is stipulated by statute. A person who...more

Global Tax News: Brazil opens consultation on how MAP provisions apply to DTT agreements

Brazil’s Federal Revenue (RFB) has opened a public consultation aimed at regulating how mutual agreement procedure (MAP) provisions apply to conventions and international agreements created to avoid double taxation....more

Criminal consequences of the use of leaked data by tax authorities

Leaks of confidential information are becoming more common. Businesses and individuals may face scrutiny by investigative agencies following leaks of information from third parties or by employees. Businesses in particular...more

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

Global Tax News: Brazil amends lists of tax havens and tax privileged regimes, clarifies "substantial economic activity"

Earlier this month, Brazil’s Federal Revenue (RFB) released Normative Instruction RFB No. 1,658, which amended Normative Instruction RFB No. 1,037/2010 to...more

Brexit: An Opportunity to Readjust UK Tax Policy?

The U.K. government mantra has for a number of years been: "Britain is open for business." This has been reflected in a number of areas relevant to U.K. domestic and foreign tax policy, including in a gradual reduction of the...more

The Future of U.K.-EU Trade: The Bilateral Trade Agreement Model

In the aftermath of Brexit, the United Kingdom is faced with the challenge of negotiating a relationship with the European Union that balances Single Market access with national control over the movement of goods and workers....more

UK Residential Property Tax Reforms Increase IHT Liabilities

The UK Government has published a consultation document and draft legislation relating to the reforms of UK residential property taxation that are due to take effect from 6 April 2017. The new rules mean that most UK...more

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