International Trade Tax

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

ATO Taxpayer Alert: Concerns about Certain Stapled Groups

In Taxpayer Alert TA 2017/1, the Australian Tax Office (ATO) has announced that it will be targeting arrangements which fragment integrated trading businesses, with particular emphasis on the inappropriate use of stapled...more

German Supreme Tax Court Confirms Capital Income Qualification Under Management Equity Programs – Close to a Breakthrough, But…

The German Supreme Tax Court has confirmed that a close to “market standard” Management Equity Program will be taxed on capital income principles. The decision (court number IX R 43/15) provides comfort with respect to most...more

Tax Reform in 2017? What is in Store for U.S. Businesses

With Republicans in control of the White House and Congress, one of the top priorities is tax reform. President Trump’s tax reform proposal and the House Republicans’ tax reform “Blueprint” suggest many changes to business...more

What’s New in Washington: 10 Things You Need to Know

The first four weeks of the Trump administration have brought a flurry of policy and regulatory activity through Executive Orders (EO), proposed new legislation and review of existing regulation. After eight years of the...more

When the Wall of Secrecy Collapses

Foreign Accounts, Shell Companies, Blind Trusts, Asset Protection Trusts, Offshore Trusts, Global Citizenship and US Residency are just a few of the Terms highlighted in the mega divorce proceedings of a Palm Beach County...more

Section 721(c) Partnership Regulations Arrive Just in Time

On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under Section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some...more

The IRS Targets Thirteen Issues in Its New Compliance Campaigns

On Tuesday, January 31, the IRS announced the rollout of thirteen initial compliance campaigns that will be undertaken by its Large Business and International Division (“LB&I”). These campaigns are part of a broader IRS...more

Novità in materia di direct-lending. Gli OICR di credito

In data 23 dicembre 2016, Banca d'Italia ha integrato il regolamento sulla gestione collettiva del risparmio (il "Regolamento") con cui, inter alia, viene data attuazione all'art. 46-ter del d.lgs. n. 58/1998 ("TUF"),...more

US: Proposed "Border Adjustment Tax” could kill foreign IP holding companies

With President Trump in the White House and a Republican majority in both the House and Senate, tax reform is once again high on the agenda. Several weeks ago, President Trump promised “a tax reform bill that will reduce our...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Key Takeaways: Inside the White House and Capitol Hill — The Impact of a New Administration on Global Markets

On January 25, 2017, Skadden hosted a panel discussion at the London Stock Exchange on the potential policy direction of the Trump administration. The panel touched on tax reform, trade agreements, inbound and outbound U.S....more

The Australian Government significantly expands ATO powers to fight multinational tax avoidance: Legislation introduced for 40 per...

Introduction and overview - The Australian Government introduced legislation (DPT legislation) into Parliament on 9 February 2017 to implement a further component (second limb) of the United Kingdom–style diverted...more

MoFo Tax Talk: Volume 9, Issue 4

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

Corporate and Financial Weekly Digest - Volume XII, Issue 6

SEC/CORPORATE - Acting SEC Chair Directs Staff to Reconsider Pay Ratio Disclosure Rule - On February 6, the acting Securities and Exchange Commission Chairman, Michael Piwowar, issued a statement soliciting public...more

Customs. Major Russian legislation changes for 2016

We would like to present the overview of the most important legislation changes in customs for 2016....more

Border Adjustment Tax

The House Republicans have proposed sweeping changes to the U.S. tax system, specifically that income from the export of goods, services and intangibles will not be subject to federal income tax, and that the cost of such...more

Ukraine and USA signs treaty on FATCA (Ukrainian)

On 7 February 2017, the Minister of Finance of Ukraine and the US Ambassador to Ukraine signed a treaty on Ukraine’s performance of the US Foreign Account Tax Compliance Act (FATCA) (the Treaty). According to the Ministry of...more

Under the Dome: Inside the Maine State House

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. State’s Highest Court to Consider Solemn Occasion Request - Last week the Senate asked the...more

Birds-Eye View of New Gain Recognition Rules on Transfers of Appreciated Property to Partnerships with Related Foreign Partners

The IRS recently issued extensive regulations under the authority of Section 721(c) that denies nonrecognition treatment for transfer of appreciated property to a controlled partnership (domestic or foreign) by a U.S. person...more

Is Your Customs Compliance BEPS Ready?

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

Night Note: The 1st 100 Days

President Trump and the Republican Congress have consistently raised the notion of a “border tax” to address trade imbalances. While the President has advocated a border tax of 20% on imports from Mexico, congressional...more

VAT deductions for active holding companies restricted by CJEU

On 12 January 2017, the Court of Justice of the European Union (CJEU) ruled that the VAT deductions on procured services by a holding company may be limited if such a holding company does not charge its subsidiaries for those...more

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

Treasury Releases Proposed Rules Implementing Partnership Audit Regime; Awaiting Publication in the Federal Register

On January 18, 2017, the Department of Treasury (“Treasury”) released proposed regulations (REG-136118-15) (the “Proposed Regulations”) implementing the partnership audit provisions of the Bipartisan Budget Act of 2015 (the...more

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