International Trade Tax Science, Computers & Technology

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.
News & Analysis as of

Congress Returns from July 4th Recess - What to Expect in the Coming Months

Although the 113th Congress continues to see a dearth of legislation seeing final approval, over the past six months, Congress has managed to finalize Fiscal Year 2014 appropriations; address the Sustainable Growth Rate...more

Intangible Services, Rights And Digital Content: Global VAT Guide

Welcome to DLA Piper’s Global VAT Guide: Cross Border Supplies of Intangible Services, Rights and Digital Content. As business grows more global, the challenge for in-house counsel and in-house VAT specialists is...more

Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 2014

The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more

Corporate Inversions Showing No Signs of Slowing Down

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or...more

Bitcoin Reportability and Taxation

June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more

Bitcoins Do Not Require FBAR Filing

I have been posting a lot of FBAR-related posts lately. Here’s one more. There has been a question whether owners of “bitcoins” and other virtual currencies that have non-U.S. aspects, are subject to annual reporting...more

Delhi High Court upholds Centrica ruling: employee secondment may trigger permanent establishment

Multinationals with operations in India should take note of the Delhi High Court’s recently decision in Centrica India Offshore Pvt Ltd., in which it upheld a ruling of the Authority for Advance Rulings that an employee...more

Regulation Of Bitcoin Around The World

Governments and tax authorities continue to develop their fiscal and tax positions relating Bitcoins. Many countries are releasing warnings about the risks associated with the use of Bitcoins, with some providing more...more

Inversion Transactions Likely to Continue and Expand into Other Markets and Industries

During recent months there has been a surge in cross-border M&A activity in which U.S. and non-U.S. companies combine in so-called inversion transactions. Examples of these transactions are Endo International’s acquisition of...more

Recent Changes In Tax Legislation (Ukraine)

The law of Ukraine ?1166-VII "On Prevention of the Financial Disaster and Creation of the Grounds for Economic Growth in Ukraine" was adopted by the parliament on 27.03.2014 and signed by acting president on 31.03.2014. As a...more

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

40 Results
|
View per page
Page: of 2

Follow International Trade Updates on: