International Trade Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.
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First bank resolution announced by DOJ: US taxpayers advised that time is running out to come forward

On March 30, 2015, the US Department of Justice announced the first non-prosecution agreement entered into by a Swiss bank pursuant to the Swiss Bank Program and advised US taxpayers with secret offshore bank accounts that...more

Potential refund of Swedish withholding tax: opportunity for US RICs

In 2012, the Swedish Administrative Court of Appeal concluded that Sweden’s withholding tax rules are not compatible with EC law when Swedish withholding tax is levied on dividend payments made to a Luxembourg SICAV fund. ...more

Luxleaks - Challenging the challenges to tax rulings in the EU

The European Commission's recent state aid crusade against so-called sweet deals in the form of tax rulings may have unwelcome consequences never contemplated by the Commission....more

Switzerland introduces corporate tax reform III aiming to maintain its global competitiveness: 6 key points

Anticipating ongoing pressure from the European Union and the OECD, Switzerland has launched a draft corporate tax reform, called CTR III, focusing on increasing the competitiveness of Switzerland as a global corporate...more

Ex-Credit Suisse Bankers Sentenced to Probation in Exchange for Cooperation

On March 27, 2015, a judge in the Eastern District of Virginia sentenced former Credit Suisse bankers Josef Doerig and Andreas Bachmann to five years of probation. Their sentences were the result of their cooperation with the...more

DOJ Announces First Swiss Bank to Reach Resolution Under Swiss Bank Program

Today the Justice Department announced that BSI SA of Lugano, Switzerland, one of the 10 largest private banks in Switzerland, is the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program....more

UK Tax Rules on Disguised Investment Management Fees: Final Legislation Published

The UK's Finance Bill was published on 24 March 2015. It was subsequently enacted on 26 March 2015 without further amendment and became the Finance Act 2015. The "disguised investment management fee" provisions contained in...more

Cayman issues User Guide to Automatic Exchange of Information Portal

As noted in an earlier update, the deadline for the registration of Cayman Islands Financial Institutions with the Cayman Islands Tax Information Authority was recently extended to 30 April 2015. In anticipation of the...more

UK Film & Television

Tax relief changes announced for film and television and a new coproduction treaty. The UK Government published the Finance Bill 2015 on 24 March 2015. We set out below the bill’s key impacts on the UK film and...more

Draft legislation released covering changes to the employee share scheme tax regime

The Australian Government has today introduced the draft Tax and Superannuation Laws Amendment (Employee Share Schemes) Bill 2015 containing measures designed to ease the tax impost for employee shares schemes, to make...more

Australian Tax Alert - Investment Manager Regime (IMR) – Draft Legislation To Implement Element 3 Finally Released

The exposure draft (ED) legislation removes tax impediments for foreign investors investing into Australia in order to attract foreign investment and promote the use of Australian fund managers. OVERVIEW - The...more

BVI issues updated FATCA Guidance Notes

The International Tax Authority (ITA) of the British Virgin Islands has recently announced the issue of Version 2.0 of the Guidance Notes on the International Tax Compliance Requirements of the Intergovernmental Agreements...more

Due Date for FATCA Reporting of US Accounts Is Approaching

The deadline to report US accounts by offshore funds that are organized in Model 2 Intergovernmental Agreement (IGA) jurisdictions, such as Bermuda, as required by Foreign Account Tax Compliance Act (FATCA), is quickly...more

Corporate Alert: China’s New Tax Regulation on Indirect Disposals Complicates Certain Offshore M&A Deals

In 2009, China’s State Administration of Taxation (SAT) promulgated Circular 698 to empower PRC tax authorities to re-characterize transfers by non-PRC residents of shares in offshore companies that hold equity interests in...more

Domestic International Sales Corporations—A Tax Saving Tool for U.S. Companies

Does your business earn income from making and exporting goods, such as agricultural products, apparel or software? If so, in connection with such exports, does your company use a “domestic international sales corporation,”...more

UK budget 2015

Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more

Orrick's Financial Industry Week in Review

European Commission Unveils Tax Transparency Package - The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national...more

European Commission Unveils Tax Transparency Package

The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national corporations. As of next year, EU members would have to declare their...more

South African Hedge Fund Regulation – Here At Last

After five years of talking about the need to regulate hedge funds as a type of financial institution in South Africa, the Minister of Finance in his budget speech stated that with effect from 1 April 2015 “hedge funds will...more

UK Budget 2015 – Key Tax Measures

The Chancellor of the Exchequer’s final Budget of the current Parliament, given on 18 March 2015, was held in the shadow of the UK’s general election on 7 May 2015. With the backdrop of the UK’s GDP growth increasing,...more

"Appeals Court Reverses IRS-Favorable Tax Court Decision in BMC Software"

On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more

Google Tax Spreading to Other Countries?

In December of last year, the UK announced a 25% tax on US multinational companies that do business in the UK but avoid paying UK tax through careful tax planning (for example, through the use of tax treaties)....more

EU Customs Practice Group

In This Issue: - EU CUSTOMS POLICY: ..Commission Report on Customs 2013 programme - TARIFFS: ..Duty suspension and tariff quotas ..EU duty suspension for certain heavy oils ..FTA update -...more

New Interest Rate Thresholds

On 9 March 2015 Federal Law No. 32-FZ “On Amending Part II of the Tax Code of the Russian Federation”, dated 8 March 2015, entered into force. The Law is aimed at softening the negative tax effect on borrowings resulting...more

Non resident CGT Charge

New tax charge - A new regime which will charge non-UK tax resident owners of UK residential property to capital gains tax (CGT) is due to come into force on 6 April 2015. The draft legislation was published as part of...more

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