International Law & Trade, Tax Law, Business Organization

What A Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

by Anthony Diosdi | Moskowitz LLP on 5/22/2013

When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because, it is legal. ...more

FATCA Compliance for Investment Fund Managers, Part Two

by Christopher Cawley, Nicola Lemay, Richard Schaul-Yoder | Foley Hoag LLP on 5/13/2013

This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more

Verbatim: Global Compliance - Quarterly Newsletter: Spring 2013

by Orrick, Herrington & Sutcliffe LLP on 5/10/2013

We've highlighted a few notable developments in corporate governance law taking place this spring that may be of interest to you. For more information on any of the topics listed below, please contact us at...more

Foreign Account Tax Compliance Act (FATCA) Registration

by Darren Mills | Berkeley Research Group, LLC on 5/6/2013

Beginning on December 31, 2013, the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trusts (WT) will be subject to the requirements of a foreign financial institution (FFI). As a...more

Proposed Legislation Would Sweep Certain Offshore Corporations into the U.S. Tax Net and Subject Their Worldwide Income to U.S....

by Dennis Allen, Robert S. Chase II, Jeffrey Mace, Michael Miles, William Pauls, M. Kristan Rizzolo, Carol Tello, P. Bruce Wright | Sutherland Asbill & Brennan LLP on 4/25/2013

The Stop Tax Haven Abuse Act and the International Tax Competitiveness Act of 2013 are two parts of a package of three bills introduced in the U.S. House of Representatives on April 15 by Rep. Lloyd Doggett. A significant...more

Independent Contractor or Employee: Are Independent Contractors the Best Solution for Multinational Organizations?

by Carson G. Burnham, Bonnie Pucket | Ogletree, Deakins, Nash, Smoak & Stewart,... on 4/24/2013

Almost every organization expanding overseas needs a vehicle to explore the market before making the business decision to establish a legal entity, yet few legal vehicles are available for this preliminary measure. Most...more

Market Entry: People's Republic of China

by Thomas M. Shoesmith | Pillsbury Winthrop Shaw Pittman LLP on 4/24/2013

China is the world’s second largest economy, with an annual growth rate of more than 8 percent and a rapidly growing middle class. Foreign investment into China routinely exceeds US$100 billion a year. Businesses from all...more

Cayman Islands commended by the OECD in latest peer review report

by Marco Martins | Harney Westwood & Riegels on 4/23/2013

The Organisation for Economic Co-operation and Development (“OECD”) recently published a report in which the Cayman Islands was commended for the “streamlined, efficient and responsive procedures it has is in place to...more

Considerations For International Clients Who Intend to Buy A Home In the U.S.

by Amy McEvoy | Sheppard Mullin Richter & Hampton LLP on 4/23/2013

International buyers invested $82.5 billion in U.S. residential real estate (4.8% of total U.S. sales) according to the most recent survey conducted by the National Association of Realtors for the 12 month period ending with...more

Taxpayer Challenges Validity of IRS Transfer Pricing Regulation

by Steven Hannes | McDermott Will & Emery on 4/19/2013

In a petition recently filed in the U.S. Tax Court, a taxpayer has challenged the Internal Revenue Service (IRS) regulation that provides that the IRS can reallocate income between affiliates even when foreign law prohibits...more

Third Circuit Court of Appeals Issues Landmark Decision in Virgin Islands Economic Development Program Case

by Joseph DiRuzzo | Fuerst Ittleman David & Joseph, PL on 4/18/2013

Disclosure: Joseph A. DiRuzzo, III of Fuerst Ittleman David & Joseph was part of the trial team that represented the taxpayers in the June 2010 bench trial in the District Court of the Virgin Islands....more

Cyprus: The Day After - The sun will still shine bright

by Pavlos Aristodemou | Harney Westwood & Riegels on 4/10/2013

Introduction - Cyprus has been in the spotlight recently due to the negotiations with what has become known as the troika (the International Monetary Fund, the European Central Bank and the European Commission)...more

Legal Alert: A Trend Emerging? District Court Disallows $1 Billion of Deductions

by David Cho, Thomas Cullinan, Joseph DePew, Mary Monahan, Daniel Schlueter, Jeffrey Starkey | Sutherland Asbill & Brennan LLP on 4/4/2013

Earlier this year, the United States District Court for the Middle District of Louisiana upheld the Internal Revenue Service’s disallowance of $1 billion of deductions claimed by Dow Chemical in relation to two transactions...more

Personal Use Of Corporate Property In A USRPI Holding Company Structure

by Charles (Chuck) Rubin on 4/1/2013

To insulate the ultimate individual owners from U.S. estate taxes, nonresident aliens often hold U.S. real property in a U.S. corporation, which corporation is owned by a foreign corporation. The foreign corporation is owned...more

Foreign-Based Requirement Under Section 231.6 Of The Income Tax Act Upheld By The Federal Court

by Cheryl Gibson | Dentons on 3/25/2013

The Canada Revenue Agency had an important win this week in its efforts to access information outside of Canada. On March 20, 2013, the Federal Court issued its decision in Soft-Moc Inc. v. M.N.R. 2013 FC 291, dismissing...more

In the Money – Puerto Rico Me Encanta! Puerto Rican Hedge Funds

by Gerald Nowotny on 3/18/2013

Overview - Every financial media outlet (including Bloomberg and the Wall Street Journal) in the last several weeks has run an article on the possibility of billionaire hedge fund manager becoming a Puerto Rican...more

NRA Gain On Sale Of Partnership Interest Treated As Creating Effectively Connected Income

by Charles (Chuck) Rubin on 3/18/2013

Nonresidents are generally not subject to U.S. income taxes on their capital gains if present in the U.S. for less than 183 days in the tax year. Code Section 741 treats the gain from the sale or exchange of a partnership...more

India Budget 2013: Key Changes Affecting International Investors

by George Cyriac, John Lillis, Kartick Maheshwari, Peita Menon, Prabhu Narasimhan, Nandan Nelivigi, Ray Simon | White & Case LLP on 3/15/2013

On February 28, 2013, India’s Finance Minister presented the country’s budget for the fiscal year beginning April 1, 2013 (Budget). The Budget includes several proposals that affect international investors investing in India,...more

Closing Corporate Tax Loopholes: A Good Idea?

by Adriana Clamens | Michael Diaz Jr. - Diaz Reus International... on 3/4/2013

One of the most heated debates among Americans is whether to close the so-called corporate loopholes. However, there is wide misconception as to what exactly are “tax loopholes.” According to Eric Toder, co-director of the...more

Fiscalité Droit des sociétés Dubai Emirats Arabes Unis

by Kocks & Partners Rechtsanwälte Belgien on 2/26/2013

Types de sociétés aux Emirats Il existe 3 types de sociétés aux Emirats Arabes Unis: Société? « Offshore » Pour des activités exclusivement en dehors des Emirats (pas de client et de fournisseur, ni de bureau, ni de...more

Amendments to Kazakhstan’s Registration Law

by Ainur Kaipova, Vladimir Shuster, Aset Shyngyssov | Morgan Lewis on 2/14/2013

Key changes affect the registration and re-registration of legal entities in Kazakhstan. ...more

Financial Services Tax – UK Update from Dechert’s Tax Group: Rule Changes Yield Mixed Blessings for UK Investors in Offshore Funds

by David Gubbay, Daniel Hawthorne, Mark Stapleton | Dechert LLP on 2/11/2013

UK investors in closely held offshore funds can be directly liable for tax if the fund makes a gain on an underlying asset even if the gain is reinvested by the fund and not distributed to the investor. There is also the...more

Marketing Intangibles in International Transfer Pricing

by Claire M.C. Kennedy | Bennett Jones LLP on 1/29/2013

An Indian tax appellate tribunal has recently ruled on the issue of marketing intangibles in a transfer pricing case involving the Indian manufacturing and sales subsidiary of the Korea-based LG Electronics Inc. In that case,...more

The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate... [Video]

by JD Supra Law News on 1/24/2013

Watch our latest Corporate Law Report for: - a speed round of need-to-know employment law advisories covering workplace secret recordings, the EEOC's strategic enforcement plan, the NLRB in Obama's second term, and more; -...more

UK property tax changes: “de-enveloping” or a use of a trust?

by Henry Mander, Colin Riegels | Harney Westwood & Riegels on 1/21/2013

It has long been popular for high net-worth people who are not domiciled in the United Kingdom (“non-doms”) to form an offshore company, often in the British Virgin Islands (“BVI”), for the purposes of holding property in the...more

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International Law & Trade › Tax Law › Business Organization

What A Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

FATCA Compliance for Investment Fund Managers, Part Two

Verbatim: Global Compliance - Quarterly Newsletter: Spring 2013

Foreign Account Tax Compliance Act (FATCA) Registration

Proposed Legislation Would Sweep Certain Offshore Corporations into the U.S. Tax Net and Subject Their Worldwide Income to U.S....

Independent Contractor or Employee: Are Independent Contractors the Best Solution for Multinational Organizations?

Market Entry: People's Republic of China

Cayman Islands commended by the OECD in latest peer review report

Considerations For International Clients Who Intend to Buy A Home In the U.S.

Taxpayer Challenges Validity of IRS Transfer Pricing Regulation

Third Circuit Court of Appeals Issues Landmark Decision in Virgin Islands Economic Development Program Case

Cyprus: The Day After - The sun will still shine bright

Legal Alert: A Trend Emerging? District Court Disallows $1 Billion of Deductions

Personal Use Of Corporate Property In A USRPI Holding Company Structure

Foreign-Based Requirement Under Section 231.6 Of The Income Tax Act Upheld By The Federal Court

In the Money – Puerto Rico Me Encanta! Puerto Rican Hedge Funds

NRA Gain On Sale Of Partnership Interest Treated As Creating Effectively Connected Income

India Budget 2013: Key Changes Affecting International Investors

Closing Corporate Tax Loopholes: A Good Idea?

Fiscalité Droit des sociétés Dubai Emirats Arabes Unis

Amendments to Kazakhstan’s Registration Law

Financial Services Tax – UK Update from Dechert’s Tax Group: Rule Changes Yield Mixed Blessings for UK Investors in Offshore Funds

Marketing Intangibles in International Transfer Pricing

The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate... [Video]

UK property tax changes: “de-enveloping” or a use of a trust?

The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate... [Video]

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