International Trade Tax Securities

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Bandfield Confirms Aggressive FATCA Enforcement Tactics

On Sept. 9, 2014, in U.S v. Robert Bandfield et al., federal prosecutors in the Eastern District of New York announced the indictment of a U.S. citizen and others, including offshore corporate service providers (CSPs) and...more

FATCA Violation Underlies Latest US Tax and Securities Fraud Charges

Indictment demonstrates the strength of US law enforcement efforts to combat offshore fraud and is the first to charge a FATCA violation. On September 9, 2014, in US v. Robert Bandfield, et al., federal prosecutors in...more

New Amendment To The France-Luxembourg Tax Treaty: Capital Gains On Sale Of Real Estate Entities Will Be Taxable In The State...

Based on the press release issued by the Luxembourg Ministry of Finance (MoF), the amendment allocates the right to tax capital gains realised upon the sale of stock, shares or other rights in companies, trusts or any other...more

Investment in French real estate: France-Luxembourg double tax treaty changes

On 5 September 2014, the Governments of France and Luxembourg signed an amendment to the France-Luxembourg treaty dated 1 April 1958 (the “Treaty”), which will have an impact in the future for certain investments in French...more

How Windstream Ruling Will Affect Foreign Taxpayers

In general, a REIT is a special purpose entity for U.S. federal income tax purposes that requires at least 75 percent of the value of the entity’s gross assets to consist of real estate assets, cash, cash items, and...more

SEC Issues Interpretive Advice About Verification Safe Harbors Under Rule 506(c)

The availability of the private placement exemption under SEC Rule 506 depends in large measure upon determinations that purchasers are “accredited investors” under the rules. Where there is no general solicitation, Rule...more

Italian Government Enacts Innovative Measures to Support Access to Finance

A new decree expands the types of entities allowed to provide loans beyond banks and financial intermediaries. Introduction - The Italian Government enacted law decree No. 91, of June 24, 2014, published on...more

Banking & Financial Services E-Note

In This Issue: - 70 Countries Agree to Share Bank Information in Tax Evasion Probe - Financial Industry Pushes Back Against Proposed ERISA Requirements - Federal Reserve Proposes Tougher Stress Tests for...more

Orrick's Derivatives in Review - July 2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

Affirmative Use of U.S. Partnerships in Inbound Tax Planning

A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC...more

Pre-Filing Consultation of SEC Staff Regarding Venezuela Operations May Be Appropriate in Certain Circumstances

In a recent meeting, a representative of the SEC accounting staff noted that the SEC staff is focusing on how companies with operations in Venezuela are affected by the various foreign currency exchange mechanisms in...more

Financial Regulatory Developments Focus - June #3

In this issue: - Compensation - Capital and Prudential Regulation - Bank Structure - Financial Services - Consumer Protection - Enforcement - People - Events...more

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more

Credit Suisse Pleads Guilty to DOJ Charge of Conspiracy to Aid Tax Evasion; FRB and NYDFS Take Related Actions

As widely reported in the financial press, Credit Suisse AG (“Credit Suisse”), a large Swiss bank that maintains a branch and other offices in the United States pleaded guilty to the felony of conspiracy to aid tax evasion by...more

The High-Tax Exception And Malta’s Refund System

A Match Made in Heaven - U.S. shareholders of foreign corporations are generally not subject to U.S. federal income tax on the earnings of such corporations until those earnings are repatriated to the shareholders in...more

Key issues for asset managers in 2014

In this newsletter - U.S.: - Dodd-Frank Act – Designation of asset managers as systemically important financial institutions - Volcker Rule finalised with a more limited application to covered fund activities...more

LSTA Publishes Revised Documents Effective April 24, 2014

The Loan Syndications and Trading Association (LSTA) has released new forms of its primary trading documents, effective for trades entered into on or after April 24, 2014. The LSTA's updated forms are primarily...more

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

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

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