International Trade Tax Securities

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Doing Business in Latin America and The Caribbean: Columbia

Colombia is located in the northernmost part of South America. Its population is estimated at over 45 million people, with at least 10 million living in the capital city of Bogotá. Colombia’s main language is...more

Doing Business in Latin America and The Caribbean: Cayman Islands

The Cayman Islands are located in the western Caribbean Sea about 480 miles south of Miami and 180 miles northwest of Jamaica. Of the three islands, Grand Cayman is the largest with an area of 76 square miles. The islands of...more

A SWISS PRINCIPAL MODEL CASE STUDY: RESTRUCTURING A MULTINATIONAL CORPORATION THROUGH TERRITORIAL OPTIMIZATION

The Swiss Principal model has become an effective means to optimize the structure of multinational companies on a regional basis, maximizing efficiencies by restructuring EMEA-area procurement, distribution and sales...more

IRS PFIC Regs

The IRS issued definitions and reporting requirements for shareholders of passive foreign investment companies (PFICs) effective December 31, 2013 for US tax returns for 2013 and onwards. The regulations provide guidance for...more

Netherlands: tax treatment of hybrid finance instruments in the wake of two landmark cases

The Dutch Supreme Court has given its judgment in two landmark cases regarding the classification of hybrid finance instruments. The question in both cases was whether shares can be requalified as a debt instrument for...more

FATCA – It’s Here, It’s Not Going To Be Delayed And Action May Be Needed By April 25, 2014. Is Your Fund Ready?

FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more

The Camp US tax reform proposal: what’s inside?

House Ways and Means Committee Chairman Dave Camp (R-Michigan) this week introduced a draft of the most comprehensive reform of the Internal Revenue Code in decades. The key principles in the draft are: (1) a...more

Spain’s Basque Country extends participation exemption regime to capital gains on transfer of shares in Spanish companies

Spain’s autonomous Basque Country region has extended its participation exemption regime (applicable to foreign participations) to capital gains derived from the transfer of shares in Spanish companies (dividends were already...more

Successful Strategies For Doing Business In Asia: India

1. What role does the government of India play in approving and regulating foreign direct investment? Historically, India has been a regulated economy since its independence. The government of India (GOI) launched a...more

Pubblicato In G.U. Il Decreto Legge Sulla Voluntary Disclosure Per Il Rientro Dei Capitali All'estero

Il decreto legge 28 gennaio 2014, n. 4 (pubblicato in G.U. n. 23 del 29 gennaio 2014 – di seguito "Decreto") introduce nel d.l. 167/1990 (in materia di "Rilevazione ai fini fiscali di taluni trasferimenti da e per l'estero di...more

"Government Enforcement: Aggressive Efforts Continue Around the Globe"

Government enforcement efforts in 2013 produced major settlements of matters relating to the global financial crisis, high-profile insider trading convictions, near-record amounts of FCPA settlements, and new pledges of...more

New Temporary Regulations Expand Reach of U.S. Anti-Inversion Rules and Permit De Minimis Continuing Ownership in Foreign Acquirer

On January 16, 2014, temporary regulations were issued by the U.S. Department of the Treasury and the Internal Revenue Service (IRS) with respect to corporate inversions under Section 7874 (the "New Regulations"), which...more

Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons

Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more

Private Funds In Focus - Winter 2014

Year End Update – Compliance: Certain Upcoming U.S. Regulatory Deadlines - The list below briefly summarizes various regulatory obligations and filing deadlines for private fund managers under U.S. rules....more

Bitcoins: More Guidance From The CRA

Tax authorities around the world continue to wrestle with the tax issues arising from the use and sale of Bitcoin currency. Sweden recently announced that it will treat Bitcoin as an asset, and Finland has stated that it will...more

DQ’d: New Inversion Regulations Expand the Reach of the Public Offering Rule and Offer a Few Other Surprises

On January 17, Treasury and the IRS published new temporary and proposed regulations under Section 7874 of the Internal Revenue Code that expand the reach of the so-called “public offering rule” of Section 7874(c)(2)(B) to...more

Orrick's Derivatives in Review - January 2014

Industry Groups File Lawsuit Challenging Cross-Border Guidance - On December 4, 2013, the Securities Industry and Financial Markets Association, the International Swaps and Derivatives Association, Inc., and the...more

Sale of dividend claims to third parties by non-resident taxpayers

Federal Ministry of Finance: If the capital gain is not taxable in Germany, the correspondent dividends are taxed. With its circular letter dated 26 July 2013, the Federal Ministry of Finance comments on the tax...more

IRS Releases Final and New Proposed Regulations That Define “Dividend Equivalent” for U.S. Withholding Tax Purposes

On December 5, 2013, the Internal Revenue Service (“IRS”) finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid...more

The Financial Report - Volume 2, No. 22 • December 12, 2013 (Global)

OSC to hold derivatives reporting seminar. The Ontario Securities Commission announced that it will hold a seminar on January 15, 2014, on the reporting requirements under the new Derivatives Trade Repositories and...more

New Proposed Regulations Under Section 871(m) Adopt a Single Factor Test but Delay Effective Date Until 2016

On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

District Court Rules for Taxpayer in STARS Case Santander Holdings; Court of Federal Claims Rules for Government in STARS Case...

In this issue: - Swiss Bank Settlement Dilemma - District Court Upholds STARS Transaction Ruling Payment Is Included in Pre-Tax Profit - Court of Federal Claims Holds for Government in BB&T STARS...more

Managing Offshore Holding Companies from China: Recent Case May Suggest Increased Tax Risk

As our readers know, foreign investments into the People’s Republic of China (“PRC”) are typically structured through one or more holding companies domiciled in offshore jurisdictions. Planned and implemented properly, an...more

Production Includes Growing

A U.S. shareholder of a controlled foreign corporation (CFC) has gross income on its share of the CFC's subpart F income. This income includes “foreign base company sales income” or FBCSI. ...more

Allocation of FATCA Withholding Risk in Financial Transactions Outside the United States

The U.S. Treasury Department has delayed implementation of FATCA once again. However, this delay may be the last, and a phased implementation of FATCA is scheduled to begin on July 1, 2014. FATCA introduces the potential for...more

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