International Trade Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.
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"United States: International Cooperation, Anti-Corruption and Tax Remain Key Issues for Enforcement Authorities"

U.S. authorities continue to aggressively pursue cross-border investigations and to scrutinize closely the compliance programs of multinational corporations. Investigative activity by U.S. authorities in 2014 was particularly...more

FinCEN Again Extends Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until June 30, 2016 to file the Report of Foreign Bank and Financial Accounts....more

Franchise and Distribution News - January 2015

TAKE ACTION NOW TO AVOID UNEXPECTED STATE TAX LIABILITIES - Traditionally, nexus for state income tax liability has required some type of physical presence or continuous contacts by the franchisor/distributor with a...more

Franchising and Liability Under the FCPA

I am often asked about franchisor liability under the Foreign Corrupt Practices Act (FCPA). Franchising has been a successful model in the US and now many corporations are looking at overseas expansion opportunities....more

"Insights Conversations: Life Sciences"

A healthy market for M&A activity, particularly cross-border deals, and a strict regulatory environment are the big factors influencing the health and activities of life sciences companies. Skadden partners John T....more

IRS Treats U.S. Fund Manager as Agent of Foreign Investor – Subjecting Investor to US Trade or Business Taxation

In CCA 201501013, the IRS found that an offshore fund making loans to U.S. borrowers was engaged in a U.S. trade or business where multiple loans owned by the fund were originated by an agent of the fund. This conclusion is...more

London Mayor Agrees to Pay IRS

According to Tax Notes Today (January 23, 2015) Boris Johnson the Mayor of London has settled tax claims of the IRS. The claim arose because Johnson who holds U.S and U.K. citizenship sold his residence at a gain and failed...more

The State Of The Union In 2015 - What To Expect From The 114th Congress

Last night, President Barack Obama delivered his sixth State of the Union Address before a joint session of the 114th Congress. Given six years to the day of his first Inaugural Address, this was his first address to a...more

China Tightens Individual Income Taxation On Capital Gains From Equity Transfer

China's State Administration of Taxation (SAT) recently promulgated the Public Announcement [2014] No. 67, Administrative Measures for Individual Income Tax on Income from Equity Transfers (for Trial Implementation) (Equity...more

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent...more

The World Wide Tax Web: FATCA Data Sharing Goes Online

The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to...more

New Russian De-Offshoring Rules. The Impact On Foreign Investors And Russian Businesses

The debate over the strength of the de-offshoring initiatives between Russian Government hard-liners and representatives of the business community seems to have been finally resolved as the Russian lawmakers have adopted...more

No Private Letter Rulings in These Estate Planning Areas

Taxpayers who have questions about the applicability of tax law can submit a Private Letter Ruling request to the IRS. If the IRS rules, then the taxpayer can rely on the ruling as to how the law applies to their situation...more

Canadian Customs Authority Shifts Gears on Import Duty Refunds

The CBSA has made a long-sought-for change in its policy to allow duty refunds in the event of qualifying downward transfer price adjustments by importers. The change comes on the heels of victory by Bennett Jones in a test...more

Canadian Importers May Now Seek Import Duty Refunds

Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party...more

Important Deadlines and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity...

Investment Advisers - Annual Compliance Reviews: All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least...more

IRS Updates Streamlined Certification Forms; Narrative Explanation Is Mandatory

The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures. The streamlined program was...more

ExxonMobil Decision by ICSID: A win for ExxonMobil or Venezuela?

On 9 October 2014, an International Centre for Settlement of Investment Disputes (ICSID) tribunal comprised of H. E. Judge Gilbert Guillaume (President), Professor Gabrielle Kaufmann-Kohler and Dr. Ahmed Sadek El-Kosheri...more

Tax: About the new import duty

On 28 December 2014 Ukrainian Parliament adopted the Law of Ukraine No73-VIII "On Measures on Stabilizing the Balance of Payments of Ukraine According to Article ??? of GATT 1994" (based on the draft law ?1562) and the Law of...more

Seventh Circuit to Motorola: No Rehearing En Banc

On December 1, 2014, we wrote about the Seventh Circuit’s decision in Motorola Mobility LLC v. AU Optronics Corp., which affirmed dismissal of the vast majority of Motorola’s claims regarding LCD panels....more

Australian Tax Alert: Bitcoin And Crypto-Currencies: Why The GST Law Should Change

The ATO released a draft ruling on the GST treatment of bitcoin transactions on 20 August 2014. A final version of that ruling, GSTR 2014/3, was released on 17 December 2014. While the ruling deals specifically with bitcoin,...more

Luxembourg Tax Authorities Confirm Tax Treatment of Limited Partnerships

The Luxembourg tax authorities have confirmed, by means of the long-expected Circular Letter L.I.R. nº 14/4 (the “Circular”), the treatment of tax transparent Luxembourg limited partnerships in the form of a société en...more

When Do Non-U.S. Citizens Pay Income Tax And Report Foreign Financial Accounts?

In a series of Frequently Asked Questions releases December 31, 2014, The Congressional Research Service provides some guidance on when non-U.S. citizens may be subject to U.S. income taxes....more

IRS Hammers Offshore Lending and Underwriting Structure

In a recent Chief Counsel Advice, in an extended analysis the IRS determined that an offshore partnership with a U.S. manager that was engaged in the finance transactions was determined to be engaged in a U.S. trade or...more

2015 Regulatory Challenges Burdening Manufacturers

As we roll into the new year, this edition of the Manufacturing Industry Advisor takes a look at some of the key regulatory issues that manufacturers will be facing in 2015. Based on recent discussions with key legislative...more

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