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Global Tax News: Brazil opens consultation on how MAP provisions apply to DTT agreements

Brazil’s Federal Revenue (RFB) has opened a public consultation aimed at regulating how mutual agreement procedure (MAP) provisions apply to conventions and international agreements created to avoid double taxation....more

Criminal consequences of the use of leaked data by tax authorities

Leaks of confidential information are becoming more common. Businesses and individuals may face scrutiny by investigative agencies following leaks of information from third parties or by employees. Businesses in particular...more

Global Tax News: Brazil amends lists of tax havens and tax privileged regimes, clarifies "substantial economic activity"

Earlier this month, Brazil’s Federal Revenue (RFB) released Normative Instruction RFB No. 1,658, which amended Normative Instruction RFB No. 1,037/2010 to...more

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

Digesting the €13 Billion Apple-EU Tax Ruling

King & Spalding experts assess what international businesses need to be aware of following the EC's ruling on State Aid in the Apple case - Partners in King & Spalding’s tax department have shared their perspectives and...more

10 Steps to Mitigate EU State Aid Exposure on Tax Arrangements

As the European Commission reviews whether tax arrangements conform with State aid rules, companies active in Europe should ensure their fiscal regimes comply with EU law. In recent years, the European Commission (the...more

Tax Alert for Foreign Investors Looking at U.S. Investments

Pre-immigration and Non-U.S. Resident Planning - It does not matter whether foreign individuals are investing in U.S. property and hoping to become residents in the U.S., or are planning to invest in U.S property...more

Overview of Luxembourg Tax Developments - September 2016 - Issue 01

This report summarizes some of the main Luxembourg tax developments that took place between the end of 2015 and August 2016. The selected developments are mainly relevant to companies and the international tax...more

Canadians Who Invested in U.S. LLPs and LLLPs Need to Rethink Their Choice of Entity

Historically, Canadian investors in U.S. partnerships benefitted from an extremely efficient income tax structure – i.e., a single level of tax, credit against Canadian taxes for taxes paid in the U.S., and an ability to...more

Amendments of CIT and PIT Acts in Poland

On 5 September 2016, the lower chamber of the Polish parliament (Sejm) accepted changes made by the Senate to the Act amending PIT and CIT. The Amendment Act has been sent to the President for signing....more

State aid – the European Commission charges forward

This note provides an update on the EU state aid decisions and aims to put recent developments in context. We review the current state of the state aid investigations, provide some political context, touch on the US...more

Ten Key Legal Issues to Consider When Moving Stateside

Stateside - Even before the uncertainties following the Brexit referendum result, a move to the U.S. was an attractive proposition for high growth UK businesses. Common language, similar culture, access to capital and a...more

EU tax ruling levies €13 billion state aid penalty on Apple

On 30 August 2016, Ireland was ordered by the EC to recover up to €13 billion from Apple on the basis that tax arrangements implemented between Apple and Ireland, originally in 1991, amounted to the provision of unlawful tax...more

The sukuk experience in Turkey

Turkey's government is determined to make Istanbul a financial hub for Islamic finance, regionally and globally. With a GDP of US$733.6 billion in 2015 according to the IMF, Turkey is the 18th largest economy in the world,...more

Battle Heats Up Over Who Can Regulate Tax on International Companies

In a decision that again pits the United States against the European Union in that ongoing battle over which entity can primarily tax international business, Margrethe Vestager, the European Union commissioner for...more

Outsourcing and the Value Added Tax: Mexico’s Third Circuit Reminds Employers to Consult the Federal Labor Law

On July 15, 2016, the Third Circuit Court on Administrative Matters, acting in plenary session (based in Jalisco), published a Judicial Interpretation titled, “Provision of Independent Services: In order to determine whether...more

Offshore Enforcement Remains Top Priority of DOJ

Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivers remarks regarding the tax division's offshore tax enforcement efforts at the Panama Bankers Association Anti-Money-Laundering Conference...more

Dubai Airport Freezone Authority

Dubai Airport Freezone (DAFZA) is one of the region’s fastest growing Freezones. Established in 1996, DAFZA is home to over 1,450 companies, covering a range of key industry sectors, including aviation, freight & logistics,...more

No Obligation to File Inaccurate Return to Avoid Failure to File Penalty

A partnership was a partner in a Cayman Islands partnership - that investment made up most of its assets. The Cayman Islands partnership did not file a Form 1065 income tax return and did not give a Form K-1 to the taxpayer...more

Puerto Rico's Act 20 and Act 22 – key tax benefits

In the midst of a complicated fiscal situation, Puerto Rico continues to attract investors and companies through two extant tax incentive packages: Puerto Rico’s Act 20 – the Promotion of Export Services Act –  and Act 22 –...more

Withholding Tax Contrary to EU Law: The Brisal Case

On 13 July, the Court of Justice of the European Union (CJEU) released its decision in the Brisal case (C-18/15). The Brisal case has potentially far reaching implications for European Union (EU) businesses that either...more

OECD BEPS Working Groups issue three discussion drafts

The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released three documents: its proposed updated guidelines on the application of the transactional profit split, draft...more

Development of the practice on assessing of withholding tax on interest income (coupon yield) payable by a Russian company for...

On 29 June 2016 the Commercial Court of Moscow rendered a decision in the case No. ?40-178650/15-75-1487 under the application of Gazprombank JSC (the “Bank”). The decision contains a number of findings that in future may be...more

Masala bonds - A taste of things to come?

Borrowing by Indian companies from the overseas market or 'External Commercial Borrowings' (commonly referred to as ECBs), is regulated by the Reserve Bank of India (RBI) and is governed by the various rules specified by the...more

China makes major changes to transfer pricing documentation and country-by-country reporting requirements

China’s State Administration of Taxation (SAT) on 13 July released on its website guidance that makes substantial changes that apply to multinationals’ transfer pricing compliance obligations for the 2016 fiscal year....more

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