International Trade Tax Science, Computers & Technology

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Tax Talk -- Volume 7, No. 1 -- April 2014

In This Issue: - FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs - No Rule Policy on MLPs - IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m) - Rev....more

IRS Says Bitcoin Isn’t Money

On March 25, 2014 the IRS issued Notice 2014-21, which describes how the IRS will interpret existing general tax principles to apply to transactions using “virtual currencies” such as Bitcoin. This Notice is the most recent...more

IRS: Bitcoin Not A Currency For Tax Purposes

As expected, the U.S. Internal Revenue Service has provided some guidance on the U.S. tax treatment of Bitcoin. In Notice 2014-21 (March 25, 2014), the IRS stated that Bitcoin is property and not currency for tax...more

Update: EU VAT on E-Commerce

There are a great variety of electronically provided services (“e-services”) and the respective market is rapidly growing. The general definition is that e-services are services which are delivered over the Internet or an...more

The European Technology Index: Technology – An engine for growth?

In 2012, in light of the Euro crisis and uncertainty of a double dip recession, DLA Piper launched the first Tech Index survey. This was to review the perceptions and attitudes of European technology growth in light of market...more

The Boricua Option – The Taxation of Incentive Stock Options (ISOs) as a Puerto Rican Resident - Another Good Reason to Move to La...

Overview - Many professional living and working in Silicon Valley over the last twenty years have become very wealthy as a result of their participation in company stock options plans – qualified and non-qualified....more

The McKesson Case – A Holiday Gift From Justice Boyle Of The Tax Court Of Canada: Ask And You Shall Receive(able) – Canada’s...

On Friday, December 20th, the Tax Court of Canada released the long-awaited and lengthy decision of Justice Patrick Boyle in McKesson Canada Corporation v. The Queen, a case involving transfer pricing adjustments under...more

Google Tax Or What Tax?

The web tax previously covered has now become more and more a Google tax given that its final approved version relates only to online ads and sponsored links, but the main issue concerns the obligations deriving from this...more

Internet Sales Tax Update

We recently reported on a case out of New York State, which dealt with the question of sales tax liability in the case of online sales. That decision (in Overstock.com v. New York Taxation Dept. and the companion case of...more

EU seeks to tighten the regulatory and fiscal net for digital companies

Introduction - The European Union (EU) has recently turned its attention to the thriving European digital economy. In two key areas, data protection and tax, the EU seeks to increase levels of regulation and impose new...more

Web tax, not just for Google

A web tax also renamed as “Google tax” aimed at obliging foreign Internet operators to pay Italian taxes is currently subject of discussion before the Italian Parliament and has raised considerable concerns also in relation...more

India: more certainty for investors, or less? Actions to take re the latest on GAAR, TP safe harbors, subsidiary PE

Recent legislative and case-law developments have clarified India’s position on a number of tax and transfer pricing issues. While many of these developments are intended to increase certainty for foreign investors, a number...more

EU: Commission starts analyzing new possible approaches of taxing the digital economy

The European Commission considers that the current taxation system was conceived in a pre-computing age so that it must be adapted in order for the digital sector to “play fair and pay fair“....more

The DOJ Ratchets Up Its Crackdown On Swiss Bank Accounts

In my last post, I discussed the possibility that Bitcoins and other virtual currencies could replace Swiss bank accounts as the tax havens of the future. Recent developments in the government’s war on offshore accounts...more

Global Tax Report - September 2013: Intellectual Property Tax Planning

In This Issue: - United States: Benefits of Intangible Property Migrations - United Kingdom: Innovation: The Name of the Game - Germany: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Within the...more

Manufacturing Innovation in America Act Introduced in House

On June 28, Rep. Allyson Schwartz (D-PA) introduced legislation (H.R. 2605) to amend the Internal Revenue Code of 1986 to allow a deduction for "patent box" profit from the use of U.S. patents (and foreign patents in certain...more

Capital Thinking Updates - June 24, 2013

In This Issue: - General Legislative - Agriculture and Food - Budget and Appropriations - Cybersecurity - Defense - Education - Energy - Environment - Financial Services - Health...more

Energy Newsletter - May 2013

In This Issue: - DISPUTE RESOLUTION: - Oil & Gas Litigation: New Decision May Impede Fracking on Federal Land - Intellectual Property: Non-Practicing Entities (Patent Trolls) Target Oil and Gas...more

Canadian Online Business Take Note: Internet Tax Case

“The world has changed dramatically in the last two decades… An entity may now have a profound impact upon a foreign jurisdiction solely through its virtual projection via the Internet.” ...more

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

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

Supreme Court of Canada Establishes Important Principles in Transfer Pricing

The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc.,1 (Glaxo), which is the Court's first pronouncement on Canada's transfer pricing rules. Transfer pricing involves the allocation...more

France Shows its Support for Innovation by Improving its Research Tax Credit (RTC) System in the Draft Finance Act for 2013

Large industrial, commercial and agricultural companies which are subject to company tax (or income tax on industrial and commercial profits) have been enthusiastic about the RTC system since its adoption. It is now proposed...more

Inside the (Patent) Box: UK Government introduces beneficial tax regime on patent income

Beginning on 1 April 2013, the UK Government will reduce the rate of corporation tax payable in the UK on profits arising from patents and some other forms of intellectual property (“IP”). The reduced tax rate implemented by...more

This Week in Washington - April 20, 2012

In This Issue: DOMESTIC POLICY MATTERS Fiscal Year (FY) 2013 Budget/Appropriations. On April 18th, Senate Budget Committee Chair Kent Conrad (D-North Dakota) revised his plan to mark up a budget resolution and...more

China 20/20: Legal & Regulatory Developments

In This Issue MOFCOM Issues Measures on Investigation and Handling of Failure on Declaration of Business Operators' Concentration Implementing Regulations for the PRC Bid Invitation and Submission Law Tax...more

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