Mergers & Acquisitions Tax International Trade

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The U.S. Announces Penalty Rates for Swiss Banks Involved in Tax Probe

The U.S. Announces Penalty Rates for Swiss Banks Involved in Tax Probe by Joseph M. Donegan on September 16, 2013 The Department of Justice unveiled a new program designed to both encourage Swiss banks to cooperate with...more

RESTRUCTURING A MULTINATIONAL CORPORATION TO IMPROVE PROFITABILITY AND EFFICIENCY

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

The Mergers & Acquisitions Review - Seventh Edition: Chapter 20: Cyprus

I GENERAL INTRODUCTION TO THE LEGAL FRAMEWORK FOR M&A - Since Cyprus’s accession to the EU, the legislation regulating M&A activity in Cyprus has been closely aligned with Europe-wide practices. Prior to...more

Use of Formula Clauses for Income Tax Advantage

In early 1985, Nestlé Holdings Inc. (Nestlé US), a first-tier wholly owned subsidiary of Nestlé S.A. (Nestlé Switzerland), acquired Carnation Co. and made an election under section 338 for that acquisition. Under section 338,...more

Euromoney Corporate Tax Handbook 2013: Mergers And Acquisitions In Ukraine: Tax Issues On The Radar

M&A in Ukraine: Tax issues on the radar - Despite the financial crises and turmoil lately there has been some pick up in M&A activity on the Ukrainian market. Originally Published in Euromoney Corporate Tax Handbook...more

Foreign Affiliate and Other Tax Changes Proposed

On July 12, 2013, federal Finance Minister Jim Flaherty released legislative proposals (the Proposals) affecting certain international tax rules in the Income Tax Act (Canada) (the ITA) and the Regulations under the ITA. The...more

Getting the Deal Through - Mergers & Acquisitions - 2013: Ukraine

1 Types of transaction: How may businesses combine? Mergers - In accordance with Ukrainian law, mergers may be performed in two ways: as a consolidation and as a joining. Both types of merger entail...more

Integrating Foreign Currency Hedges With Respect To Stock Purchase And Sale Agreements

Investment funds that invest globally must deal with volatility in the currency in which they agree to invest. Investment funds entering into obligations to purchase stock in a currency other than the primary currency of the...more

Private Equity - Winter/Spring 2013

In This Issue: - ILPA Guidelines Have Noticeable Impact - Extracting Tax Value in Debt Refinancings and Modifications - Private Equity and Venture Capital Investing in China: Exit Strategy and Circular 698 -...more

Market Entry: People's Republic of China

China is the world’s second largest economy, with an annual growth rate of more than 8 percent and a rapidly growing middle class. Foreign investment into China routinely exceeds US$100 billion a year. Businesses from all...more

Commentary on October 24, 2012: Technical Bill

On Wednesday, October 24, 2012 the Canadian Federal Department of Finance tabled in the House of Commons a large detailed Notice of Ways and Means Motion (“NWMM”) to amend the Income Tax Act (Canada) and a variety of other...more

Commentary on October 24, 2012: Notice of Ways and Means Motion Relating to Tax Matters - Acquisition of Control (subsection...

The Income Tax Act (the “Act”) contains rules that limit the ability of corporations to utilize losses and other tax attributes following an acquisition of control. Subsection 256(7) of the Act provides rules for determining...more

Canada’s Foreign Affiliate Rules: A Decade of Proposals Nearing Completion

On October 24, 2012, the Minister of Finance released a detailed Notice of Ways and Means Motion to implement outstanding technical tax amendments, including significant amendments to Canada’s income tax rules applicable to...more

Draft bill for combating RETT blocker structures

As from 2013: Real Estate Transfer tax on (in)direct economic accumulation of shares? Draft bill aiming at combating so-called RETT blocker structures - So far, all shares in a company holding German real estate can...more

Advance Dividend Payment under the Turkish Commercial Code

This document highlights basic characteristics of advance dividend payment in non-publicly traded companies under the Turkish Commercial Code....more

A Brief Comparison of Limited Liability Partnerships and Joint Stock Companies under the Turkish Commercial Code

This note aims to compare basic characteristics of limited liability partnerships and joint stock companies in accordance with the provisions of the Turkish Commercial Code and tax legislation....more

Foreign-Controlled Canadian Corporations Beware The New Foreign Affiliate Dumping Proposals

On August 14, 2012, the Department of Finance released draft legislation that includes a revised version of the foreign affiliate dumping proposals tabled with the March 29 Federal Budget. The stated objective of the...more

Mining E-Review: September 2012 - Proposed Tax Changes Negatively Affect Foreign Investments in Canadian Mining Companies

Canadian tax amendments proposed on August 14, 2012 (the Proposals) could adversely affect structures, commonly used in the mining sector, involving Canadian corporations with foreign subsidiaries....more

Proposed Tax Changes Negatively Affect Certain Foreign Investments in Canada

Canadian tax amendments proposed on August 14, 2012 (the Proposals) could adversely affect common acquisition structures for acquiring Canadian corporations with foreign subsidiaries. Investments in foreign subsidiaries by...more

Tax Structuring of Foreign Investment in South Florida Real Estate

Foreign Investment In South Florida Real Estate Heats Up According to a recent report, international buyers are driving sales at several large real estate projects in South Florida. The 200-unit Trump Hollywood sold out...more

IRS Issues Guidance on Outbound Transfers of Intangible Property in Asset Reorganizations

In Notice 2012-39 (the “Notice”), the IRS issued guidance announcing its intention to issue regulations with respect to certain transfers of intangible property by a U.S. corporation to a foreign corporation in a...more

Inside M&A - Summer 2012

In This Issue: *Focus on Family Enterprises and Family-Owned Businesses *The New Kids on the M&A Block *Top Five Traps in M&A Transactions with Family-Owned Businesses *Obtaining Maximum Value on the Sale...more

Getting The Deal Through - Mergers & Acquisitions 2012 - Cyprus

"Reproduced with permission from Law Business Research Ltd. This article was first published in Getting the Deal Through – Mergers & Acquisitions 2012, (published in May, 2012; contributing editor: Casey Cogut, Simpson...more

The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshufflings

On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final, temporary, and proposed regulations under section 7874, which provides rules governing so-called “inversion transactions.” In...more

Transfer Pricing — and it’s Impact on M&A Transactions

Originally published in ACQUISITION INTERNATIONAL 53: SECTOR SPOTLIGHT: Transfer Pricing and it’s Impact on M&A Transactions, April 2012. Mergers and acquisitions raise a whole host of transfer pricing issues from tax...more

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