Labor & Employment International Trade Tax

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IRS Simplifies Tax Reporting for Individuals With Canadian Retirement Plans

Under Article XVIII(7) of the United States-Canada Tax Treaty, a U.S. citizen or resident may elect to defer U.S. income taxation on income accruing under a Canadian registered retirement savings plan (RRSP) or registered...more

2014 Year-End Tax Update

I. A LOOK BACK AT 2014 TAX MATTERS: A. Some Random Observations - ..1. This year’s update is brought to you by the letter “I,” as in “inversions.” ..2. Tired of waiting for Congress to address what they...more

UK Finance Bill 2015 -- Draft Clauses Published

Draft clauses of the UK Finance Bill 2015 were published on 10 December 2014. They will now be the subject of consultation until 4 February 2015. This Alert provides more details on the most significant measures contained in...more

Pension News - October 2014

Welcome to DLA Piper’s Pensions News publication in which we report on recent developments in pensions legislation, guidance and case law, as well as keeping you up to speed on what to look out for in the coming...more

Australian government commits to reform tax treatment of employee stock awards: 5 takeaways for US-based companies

The Australian government has committed to reform the tax treatment of employee stock awards as part of its Industry Innovation and Competitiveness Agenda, in an effort to retain top talent and boost entrepreneurship in...more

Top of Mind - October 2014: Editor's Choice

BYOD: cool but dangerous – 3 HIPAA Security Rule challenges, 7 key precautions - Companies and employees like the idea of bring your own device (BYOD) policies that allow employees to use their personal mobiles for...more

Doing Business in Australia

With strong economic fundamentals, a positive outlook, proximity and strong trade links with some of the world’s most dynamic economies, Australia offers a wealth of opportunities for global investors and multinational...more

IRS Simplifies Procedures for Favorable Tax Treatment on RRSPs and RRIFs

The IRS has finally made it much easier for taxpayers who hold interests in either of two popular Canadian retirement plans—registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs)—to get...more

Russia: Secondment is beyond the Law?

Prior to 2014, secondment arrangements had not been clearly regulated by either Russian labor or civil law, with many Russian companies operating under the pretense that as long as it is not forbidden, it might as well be...more

Dutch Tax Plan 2015 and other changes in Dutch tax law

Today, the Dutch Ministry of Finance published its Tax Plan 2015 (hereinafter: Tax Plan). The Tax Plan primarily has an impact on citizens of the Netherlands, especially employees. The impact for the business community...more

How to Avoid Corruption Risks in China [Video]

The recent headlines on China's expanding anti-corruption investigation and enforcement action is a significant event in global anti-corruption enforcement. For companies operating in China, the risks have now increased...more

An Appreciation for Hedging Your Bets on Deferred Compensation

Under Section 457A of the U.S. Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those...more

Australia Welcomes Changes to the Australian Managed Investment Fund Regime for Foreign Pension Funds

Following its announcement in November 2013, the Australian Government has released draft legislation to enable foreign pension funds to access concessional withholding tax rates under Australia's Managed Investment Trust...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

IRS Issues Revenue Ruling on Applicability of Section 457A to Options and Stock Appreciation Rights

On June 10, 2014, the IRS issued Revenue Ruling 2014-18, which holds that nonqualified stock options, as well as stock-settled stock appreciation rights (SARs), do not constitute nonqualified deferred compensation subject to...more

IRS Ruling Allows Tax-Deferred Stock Rights for Fund Managers

Section 457A of the Internal Revenue Code (the Code) generally restricts the ability of offshore funds and other entities domiciled in tax-indifferent jurisdictions to offer tax-advantaged deferred compensation to U.S....more

An Appreciation for Hedging Your Bets on Deferred Compensation: IRS Issues Revenue Ruling 2014-18 Under Section 457A of the...

Under Section 457A of the Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those entities....more

VAT recovery and pension schemes: Where are we now?

HMRC’s policy on reclaiming VAT on investment management and other costs remains under review in the light of two recent decisions from the Court of Justice of the European Union. The first of these cases, PPG...more

Non-U.S. Retirement Plans Must Comply with or Claim Exemption from FATCA by July 1

In January 2013, the Internal Revenue Service (IRS) published final regulations under the Foreign Account Tax Compliance Act (FATCA). FATCA is intended to make it more difficult for U.S. taxpayers to conceal assets held in...more

Doing Business in Latin America and The Caribbean: Turks & Caicos Islands

The Turks and Caicos Islands (TCI) lie 575 miles southeast of Miami and 39 miles southeast of The Bahamas. There are eight principal inhabited islands which have an estimated population of 35,000. The legal system is based...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

International Transfer Window Now Open for Irish Pensions

The Irish High Court recently considered the transferability of personal retirement savings accounts (“PRSAs”) to overseas jurisdictions. This decision could have important implications for the Irish pensions industry, which...more

VAT Recovery And Pension Schemes - ATP Pension Service A/S

The judgment in ATP PensionService A/S v Skatteministeriet (Case C-464/12) was delivered by the European Court of Justice on 13 March 2014. It was the latest in a line of cases concerning the VAT treatment of costs incurred...more

Cross-Border Update on Investing and Doing Business in the United States

In this Issue: - Indian FDI into the United States - Indian Imports into the United States - Formation of US Subsidiaries - Ownership - Liability of Equity Holders - Management...more

Doing Business in Latin America and The Caribbean: Chili

Chile’s business environment is the result of a policy-driven strategy that has focused on building sound macroeconomic fundamentals and strong institutions, promoting competition and international integration, and creating a...more

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