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International Trade Tax Finance & Banking

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

Italy Addresses "Carried Interest" Tax Treatment

by Jones Day on

The Italian government has enacted Law Decree no. 50 ("Decree 50"), providing a set of new tax measures aimed at, among other things, attracting investments in Italy. Decree 50 was finally approved by the Italian Parliament...more

Donating Fund Interests: A “Why Now?” and “How To” Primer

Due to increased valuation of public and private equities, coupled with the upcoming end of the sunset provision that allows hedge fund managers to defer taxation on fees earned offshore, there is an increased interest among...more

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

by Foodman CPAs & Advisors on

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Extension and Refinement of the Aircraft Leasing Scheme in Singapore

by Morgan Lewis on

The Aircraft Leasing Scheme in Singapore is to be extended for another five years with refinements to encourage the growth of the aircraft leasing sector. On 20 February 2017, the Minister of Finance, Mr. Heng Swee Keat,...more

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers...more

Proposed Bill Seeks to Transform International Tax Evasion into Money Laundering

by Ballard Spahr LLP on

Part II of the Analysis of the Combatting Money Laundering, Terrorist Financing, and Counterfeiting Act of 2017 As we recently blogged, Senators Chuck Grassley (R-Iowa) and Diane Feinstein (D-California) introduced on May 25,...more

Tax incentives in Puerto Rico: a quick introduction

by DLA Piper on

To promote, attract and develop key industries, sectors and activities, Puerto Rico offers a spectrum of economic incentives, among them low fixed income tax rates, partial and/or total tax exemptions, income tax credits and...more

Brussels Regulatory Brief: June

by K&L Gates LLP on

On May 15, 2017, the European Commission (“Commission”) announced it had opened a formal investigation into a global pharmaceutical company for possible abuse of dominant position. The alleged conduct of the company,...more

Senators Propose the Combatting Money Laundering, Terrorist Financing, and Counterfeiting Act

by Ballard Spahr LLP on

Senators Chuck Grassley (R-Iowa) and Diane Feinstein (D-California) introduced on May 25, 2017 a bill, S. 1241, entitled the “Combatting Money Laundering, Terrorist Financing, and Counterfeiting Act of 2017.” Although it is...more

A New Draft REIT Act was Submitted

by K&L Gates LLP on

On May 26, 2017, the Ministry of Finance submitted a new draft act on real estate investment trusts dated May 19, 2017 (“Draft”). Pursuant to art. 1 section 1 of the Draft, REIT shall include joint stock companies: -...more

FATCA Update: FFI Agreement Renewal Function Now Available

by Fox Rothschild LLP on

The Internal Revenue Service announced today that its FATCA FFI Registration system has been updated to allow foreign financial institutions to renew their FFI agreement with the IRS. Those financial institutions that are...more

Three More Countries Will Now Provide IRS Information On Bank Interest Paid To Nonresident Aliens

by Fox Rothschild LLP on

The IRS recently released Revenue Procedure 2017-31 which adds Belgium, Columbia and Portugal to the list of participates in the automatic exchange of information on bank interest paid to nonresident alien individuals for...more

What’s New in Washington: 10 Things You Need to Know

Despite the headlines coming out of Washington, Congress continues to move forward in regular fashion, discussing and acting upon key issues, such as funding the government, addressing the need to raise the debt ceiling and...more

Bennett Jones Spring 2017 Economic Outlook

by Bennett Jones LLP on

In our Fall 2016 Economic Outlook, we set out at some length our analysis of the main factors which have contributed to the low “new normal” growth rates the world has experienced since 2011. We argued that trend annual...more

Let’s Just Fess Up and Agree, Loans are Dodgy Things:  FASB’s New Growth Killing Rule on Loan Losses

by Dechert LLP on

Just when you thought it was safe to go out at night again, another reason not to deploy capital is slouching into Bethlehem. We’ve written a lot here at CrunchedCredit about the Damian-like progeny of Dodd-Frank and Basel,...more

Blockchain Week in Review – May 2017 #4

by Perkins Coie on

Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more

UK Criminal Finances Act 2017: A Dechert "Dirty Money" Trilogy

by Dechert LLP on

Part One: "A Fistful of Tax Dollars" - A New Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion.. The Criminal Finances Act 2017 represents a further significant development in the approach to the...more

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

by Foodman CPAs & Advisors on

FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...more

US Banks wanting to be ahead of the FATCA game must master international tax compliance

by Foodman CPAs & Advisors on

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

The Summons

by Moskowitz LLP on

Coinbase is a San Francisco-based cryptocurrency exchange company that operates bitcoin and other digital asset transactions and storage for over one million users in 190 countries....more

Forfeiture Case Based on Alleged Elaborate $230 Million Russian Laundering and Fraud Scheme to Settle

by Ballard Spahr LLP on

On the eve of trial this past Friday, the government announced an agreement to settle, subject to court approval, a major civil forfeiture action in the Southern District of New York. In the case, United States v. Prevezon...more

Corporate and Financial Weekly Digest - Volume XII, Issue 18

SEC/CORPORATE - US District Court Holds That Discretionary Tax Withholding is Exempt Under 16b-3 - Several companies have received shareholder letters seeking to recover short-swing profits from insiders under Section...more

Corporate Criminal Offence: Failure to Prevent Facilitation of Tax Evasion

The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement...more

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