News & Analysis as of

International Trade Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.

UK Tax Round Up - July 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more

Renewal of U.S. FATCA Registration for Certain Investment Funds by Monday, July 31, 2017

Certain non-U.S. investment funds, including Bermuda funds, which qualify as foreign financial institutions (FFI), must enter into a legal agreement (“FFI agreement”) with the U.S. Internal Revenue Service (IRS) to be treated...more

Grecian Magnesite: Tax Court Finds Reliance on a US Tax Advisor Establishes Reasonable Cause

On July 13, 2017, the Tax Court, in Grecian Magnesite, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. 3 (2017), rejected Internal Revenue Service (IRS) arguments that, in order to establish good faith reliance, the...more

Tax Court Overrides Key Revenue Ruling on the Tax Treatment of the Sale of U.S. Partnership Interest by Foreign Persons

by King & Spalding on

In a July 13, 2017 opinion, the United States Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner refused to follow the long-held IRS position found in Revenue Ruling 91-32 (“the “Revenue...more

Tax Court Rejects IRS’ Position in Rev. Rul. 91-32

Grecian Magnesite Mining, a Greek corporation (GMM), owned an interest in Premier Chemicals LLC, a Delaware limited liability company classified as a partnership for US income tax purposes (Premier). Premier conducted a trade...more

People with significant control regime: expanded scope and more regular reporting

by Dentons on

Changes to the UK's regime for the disclosure by companies of their significant controllers (the PSC regime) took effect on 26 June 2017. The changes ensure that UK legislation is compliant with the EU's Fourth Anti-Money...more

Tax impact of the repeal of the foreign employment income exemption on South African professionals

by Hogan Lovells on

The Taxation Laws Amendment Bill 2017 (2017 TLAB) was published for public comment on 19 July 2017. One of the changes proposed is the repeal of the so-called foreign employment income exemption, contained in section...more

Draft tax legislation for 2017 released

by Hogan Lovells on

Following the 2017 Budget presented before Parliament on 22 February 2017, the draft tax legislation for the specific tax proposals was released on 19 July 2017 for comment. Comments should be made by 18 August 2017. ...more

Polish Ministry of Finance publishes a draft bill proposing significant changes to corporate income tax

by DLA Piper on

The Polish Ministry of Finance has published a draft bill that proposes significant changes to, among other things, the Act on Corporate Income Tax (Bill). Its aim is to close loopholes in the corporate tax system. The Bill...more

Newsflash: Tax Court Reverses IRS Revenue Ruling

by Dechert LLP on

A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more

Corporate Inversions

by Kelley Drye & Warren LLP on

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

US Tax Court Exempts Gain on Sale of a Partnership Interest

by Latham & Watkins LLP on

Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more

U.S. Exports of Whiskey, Juice, and Dairy Products to Europe Targeted for Retaliation against President Trump’s Plans to Limit...

by Hogan Lovells on

U.S. trading partners have begun to signal their plans to consider retaliatory measures in response to President Trump’s Section 232 Investigations on steel imports. In particular, European Union (EU) officials recently...more

Impact of the Multilateral Instrument on U.S. Taxpayers

by Alston & Bird on

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all...more

Office of Tax Simplification Recommendations for Reform of Stamp Duty on Paper Documents

by Goodwin on

On 10 July 2017 the Office of Tax Simplification (OTS), the independent adviser to the government on tax simplification, released its recommendations following its review of stamp duty on paper documents. Whilst the proposals...more

IRS Identifies 8 Burdensome Regulations for Reform

Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden that the...more

Treasury Dept. Identifies 8 "Significant Tax Regulations" for Review to Reduce Burden

by Holland & Knight LLP on

The U.S. Department of the Treasury announced on July 7, 2017, in Notice 2017-38 (the Notice) that it has identified as "significant tax regulations" eight sets of U.S. federal tax regulations that were issued between Jan. 1,...more

Procedure on Open Discussion of Tariffs to Be Established by the Ukrainian Regulator

by Dentons on

Please be informed that on 30 June 2017 Procedure on Carrying Out Open Discussion of Draft Decisions of the Ukrainian Regulator No. 866 (the “Procedure”), was adopted by the Ukrainian Regulator. The Procedure enters into...more

UK corporate offence of failure to prevent tax evasion

by Ropes & Gray LLP on

Andrew Howard, Ropes & Gray tax partner, discusses the UK’s new corporate criminal offence of failure to prevent tax evasion, which goes into effect in September 2017. __________ The UK's new corporate offence of failure to...more

Trade & Manufacturing Alert - July 2017

by King & Spalding on

Ambassador Lighthizer Visits Congress To Discuss The President’s Trade Policy Agenda - In June, the Senate Finance Committee and Ways and Means Committee of the House of Representatives held hearings on the new...more

Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

by Foodman CPAs & Advisors on

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations...more

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

Trade & Manufacturing - News of Note - July 2017

by King & Spalding on

Update on Border Adjustment Tax - On June 13, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) suggested a five-year phase-in for the border-adjustment tax (BAT). The BAT proposal, a key part of Republican...more

Anti-Corruption Digest - July 2017

by Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

Spain requires real-time submissions of VAT information

by DLA Piper on

Large enterprises operating in Spain are coming to terms with the latest requirements to file their VAT information on a real-time basis through the new online system set up by the Spanish tax authorities....more

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