International Trade Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.
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U.S. Tax Reform – Border Adjustment Proposal: Current Status, and How Your Company May Be Affected

On 24 June 2016, the Republican Speaker of the U.S. House of Representatives, Paul Ryan, and House Ways and Means Chairman Kevin Brady released a sweeping "Blueprint" proposal to reform the U.S. tax code. A critical component...more

EU member states reached consensus on anti-hybrid mismatch measures

On February 21, 2017, the Council of the European Union (ECOFIN, in this context) reached political consensus on a directive (known as ATAD 2) amending the EU Anti-Tax Avoidance Directive as adopted on July 17, 2016 (EU...more

Is the Border Tax Crossing the Line?

It is far too early to discern the extent of any change to the relationship between the U.S. and Mexico in the face of the oft-repeated insistence of the Trump campaign to “renegotiate” NAFTA, a promise that was reiterated...more

¿Qué Significa la Entrada en Vigor del Acuerdo de Facilitación del Comercio de la OMC?

El Acuerdo sobre Facilitación del Comercio (AFC) entró oficialmente en vigor el 22 de febrero de 2017, después de alcanzar el umbral de 110 miembros de la Organización Mundial del Comercio (OMC), o dos tercios de su...more

WTO's Trade Facilitation Agreement Enters into Force and What It Means

The Trade Facilitation Agreement (TFA) officially went into effect Feb. 22, 2017, after reaching the World Trade Organization (WTO) members' ratification threshold of 110, or two-thirds of the WTO membership. The TFA is now...more

BEPS – are you affected?

Over 100 countries and jurisdictions are collaborating through the OECD to implement measures to tackle base erosion and profit shifting (BEPS). The OECD have set out 15 actions points that aim to equip governments with the...more

Trump Wants to “Tweak” NAFTA

After meeting with Prime Minister Justin Trudeau in early February, President Trump said he plans to “tweak” the North American Free Trade Agreement (NAFTA) with Canada. Before this announcement, it was unclear whether the...more

Who Will Bear the Brunt of a NAFTA Renegotiation?

President Trump's plans to renegotiate the North American Free Trade Agreement (NAFTA) give rise to a number of questions about the future of trade between the United States, Mexico and Canada. While such a move might...more

Foreign Investment in Australia

Foreign investment is key to Australia’s economic development, and Australia welcomes it. As the fourth largest economy in the dynamic Asia Pacific region, Australia's competitive economy is set for continued expansion...more

Luxembourg CSSF Circular 17/650 - Primary tax offences - In the fight against money laundering, what are your professional...

On 17 February 2017, Luxembourg’s financial regulator (Commission de Surveillance du Secteur Financier – CSSF) issued a circular drawn up with the Financial Intelligence Unit in order to provide...more

ATO Taxpayer Alert: Concerns about Certain Stapled Groups

In Taxpayer Alert TA 2017/1, the Australian Tax Office (ATO) has announced that it will be targeting arrangements which fragment integrated trading businesses, with particular emphasis on the inappropriate use of stapled...more

German Supreme Tax Court Confirms Capital Income Qualification Under Management Equity Programs – Close to a Breakthrough, But…

The German Supreme Tax Court has confirmed that a close to “market standard” Management Equity Program will be taxed on capital income principles. The decision (court number IX R 43/15) provides comfort with respect to most...more

Tax Reform in 2017? What is in Store for U.S. Businesses

With Republicans in control of the White House and Congress, one of the top priorities is tax reform. President Trump’s tax reform proposal and the House Republicans’ tax reform “Blueprint” suggest many changes to business...more

What’s New in Washington: 10 Things You Need to Know

The first four weeks of the Trump administration have brought a flurry of policy and regulatory activity through Executive Orders (EO), proposed new legislation and review of existing regulation. After eight years of the...more

When the Wall of Secrecy Collapses

Foreign Accounts, Shell Companies, Blind Trusts, Asset Protection Trusts, Offshore Trusts, Global Citizenship and US Residency are just a few of the Terms highlighted in the mega divorce proceedings of a Palm Beach County...more

Section 721(c) Partnership Regulations Arrive Just in Time

On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under Section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some...more

The IRS Targets Thirteen Issues in Its New Compliance Campaigns

On Tuesday, January 31, the IRS announced the rollout of thirteen initial compliance campaigns that will be undertaken by its Large Business and International Division (“LB&I”). These campaigns are part of a broader IRS...more

Novità in materia di direct-lending. Gli OICR di credito

In data 23 dicembre 2016, Banca d'Italia ha integrato il regolamento sulla gestione collettiva del risparmio (il "Regolamento") con cui, inter alia, viene data attuazione all'art. 46-ter del d.lgs. n. 58/1998 ("TUF"),...more

US: Proposed "Border Adjustment Tax” could kill foreign IP holding companies

With President Trump in the White House and a Republican majority in both the House and Senate, tax reform is once again high on the agenda. Several weeks ago, President Trump promised “a tax reform bill that will reduce our...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Key Takeaways: Inside the White House and Capitol Hill — The Impact of a New Administration on Global Markets

On January 25, 2017, Skadden hosted a panel discussion at the London Stock Exchange on the potential policy direction of the Trump administration. The panel touched on tax reform, trade agreements, inbound and outbound U.S....more

The Australian Government significantly expands ATO powers to fight multinational tax avoidance: Legislation introduced for 40 per...

Introduction and overview - The Australian Government introduced legislation (DPT legislation) into Parliament on 9 February 2017 to implement a further component (second limb) of the United Kingdom–style diverted...more

MoFo Tax Talk: Volume 9, Issue 4

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

Corporate and Financial Weekly Digest - Volume XII, Issue 6

SEC/CORPORATE - Acting SEC Chair Directs Staff to Reconsider Pay Ratio Disclosure Rule - On February 6, the acting Securities and Exchange Commission Chairman, Michael Piwowar, issued a statement soliciting public...more

Customs. Major Russian legislation changes for 2016

We would like to present the overview of the most important legislation changes in customs for 2016....more

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