International Trade Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.
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HMRC publishes responses to the consultation on Partnership taxation

The result of the HM Revenue & Custom's consultation on UK partnership taxation was released on 20 March, this is important for both fund partnerships and fund managers structured as LLPs which file UK tax returns. Although...more

Senegal's New Mining Code

Senegal has officially introduced its new mining code, which has been a work in progress since 2012 when proposals were first made to revise the former mining code introduced in 2003. In recognising the potential that the...more

Getting Into Compliance with Your Foreign Account Reporting, Part II

In Part I, we listed some of the penalties associated with the failure to report foreign accounts, and what is widely regarded as the best option for coming into compliance – the Offshore Voluntary Disclosure Program (OVDP)....more

Getting Into Compliance with Your Foreign Account Reporting, Part I

With the 2015 release of the “Panama Papers,” roughly 11.5 million documents detailing personal financial information of wealthy individuals and identifying nearly 215,000 offshore entities are now available to government...more

Brexit customs update

In the month that the Government is expected to trigger Article 50 to start the process of the UK's exit from the EU, a report from the House of Commons International Trade Committee (the International Trade Committee) has...more

Ukraine ratifies the Double Tax Treaty with Luxembourg and a Free Trade Zone Agreement with Canada (Ukrainian)

On 14 March 2017 the Ukrainian Parliament passed two laws for On 14 March 2017 the Ukrainian Parliament passed two laws for ratification of two important international treaties...more

Ukraine ratifies the Double Tax Treaty with Luxembourg and a Free Trade Zone Agreement with Canada

On 14 March 2017 the Ukrainian Parliament passed two laws for ratification of two important international treaties...more

Can the IRS Revoke Your Passport?

Executive Order 13769, President Trump’s notorious travel ban that caused mass confusion and chaos in airports throughout the country, is being revamped following multiple federal court challenges. That travel ban, however,...more

Tightening the Tax Screws on International IP Structures

For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more

Reporting Foreign Income: Four Common Misconceptions

The U.S. government has stringent reporting requirements when it comes to foreign assets and income, but many people are still not coming into compliance based on some mistaken beliefs. Here are four common misconceptions...more

Next off the block - AEOI

You might have thought you have enough on your plate getting to grips with anti-money laundering rules closely followed by FATCA – but it's not over yet! Next off the block is the Automatic Exchange of Financial Account...more

Important New Business Tax Proposals for U.S. Tax System

During the past few months, there has been considerable speculation over potential changes to the U.S. tax system that could have an impact on international businesses. At this stage, the discussions are preliminary and the...more

IRS Issues Draft Form and Instructions for Country-by-Country Reports

Country-by-Country (CbC) reporting is now generally required for the ultimate parent of a U.S. multinational enterprise (MNE) for tax years that begin on or after June 30, 2016. On January 11, 2017, the IRS released a draft...more

Predicting the Unpredictable: Will Tariffs Under President Trump Cause a Trade War With China?

President Trump has stated that he would impose tariffs on imports from China ranging from ten to forty-five percent. Can he do it? And will it cause a trade war? The Effects of Increased Tariffs - In the 18th...more

Meeting the challenges of Customs compliance: 11 questions to ask yourself, 6 action steps

In the global environment in which we operate, exchanging goods internationally always entails basic customs issues.  Among these are the import/entry process, tariff classification, valuation, country of origin labeling, and...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue...

If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number (EIN) and maintain adequate books and records to...more

The U.S. Tax Reform and the Energy Sector

President Donald Trump and Republican Congressional leaders have promised a major reform to the U.S. tax code in 2017. This reform, if anything close to these promises, will have significant implications for the energy...more

Your Daily Dose of Financial News

There’s been a bit of a stir in the paint world, with Dutch firm Akzo Nobel rejecting a takeover bid from PPG Industries valued at $22 billion. In a statement, Akzo claimed that the offer “substantially undervalues” the...more

House Blueprint’s Destination-Based Cash Flow Tax: A Primer

The election of Donald Trump in November has substantially increased the likelihood of major tax reform in the near future. While it is uncertain what shape such reform will take, there has been renewed interest in the...more

Auf Wiedersehen to the tax privilege on restructuring gains – a blow to the German restructuring tool kit

A recent judgment of the German Federal Fiscal Court (FFC) will have significant impact on the restructuring tool kit afforded under German law. The FFC has found that the existing practice of permitting a tax liability...more

The introduction of GST to India - What businesses should look out for in 2017

The Constitution Amendment Bill for Goods and Services Tax (GST) has been approved by The President of India and the GST council have decided to enforce GST from 1st July 2017....more

2016 Foreign Bank Account Reports: New Filing Deadline

The U.S. government continues to pursue aggressively individuals and businesses for the failure to report foreign accounts and other non-U.S. assets. In particular, and with limited exceptions, all U.S. individuals and...more

Funds Bulletin - February 2017

Funds Bulletin (a monthly round-up of topical legal, regulatory and tax issues affecting the fund industry). Features our summary of the FSCP's position paper on the impact of Brexit on financial services consumers, as well...more

New Tax Filing Deadlines Affect Unsuspecting LLCs and Partnerships For 2017

Several tax bills passed by Congress late in 2015 changed the deadlines for filing federal income tax returns for partnerships and most limited liability companies, which are treated as partnerships for tax purposes. Other...more

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