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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

Funds Investing in U.S. Manufacturing Companies: Foreign Investor Considerations

Operators of manufacturing companies, especially those considering a sale or capital raise, should understand investors’ concerns regarding direct investment. Today, investment funds with investors and investments in multiple...more

Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal  [Video]

In this interview with The Deal’s Jon Marino, Pepper Hamilton LLP's Joan Arnold, a partner who heads the firm's tax group, says Pfizer’s play for AstraZeneca isn’t the only inversion deal being sought. There are no shortages...more

IC-DISC Benefits Enhanced with Foreign Shareholders

Since the reduction in the individual tax rate on qualified dividends in 2004, the Interest Charge Domestic Sales Corporation (“IC-DISC”) has become an attractive vehicle to obtain a tax incentive for exporting U.S.-produced...more

Summary of IC-DISC Tax Benefits

Interest-Charge Domestic International Sales Corporations (“IC-DISCs”) offer significant potential tax benefits for U.S. companies that export U.S. manufactured products or certain engineering or architectural services with...more

EU Adopts a Parent-Subsidiary Directive Amendment on Hybrid Loans

On July 8th 2014, the European Union’s Economic and Financial Affairs Council (ECOFIN) adopted an amendment to the Parent-Subsidiary Directive (PSD). This amendment is targeted at cross-border hybrid loans and aims to...more

Inbound U.S. Tax Planning With Inversions

With all of the recent negative publicity focused on the outbound restructuring of U.S. multinationals engaging in so-called “inversion” transactions (see prior blog “Corporate Inversions Showing No Signs of Slowing Down”),...more

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

Foreign Tax-Exempt Organizations Exempt from Withholding Tax

Investment funds, including private equity funds, often receive capital contributions from tax-exempt organizations. These tax-exempt institutions may include U.S. and foreign pension funds, as well as U.S. and foreign...more

McKesson: Appellant’s Factum Filed

On January 10, 2014, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14)....more

Congress Turns Tax World Upside Down with New Focus on Corporate Inversions

Interest in corporate inversions has revived on Capitol Hill. Recent publicity surrounding pending deals has triggered comments and legislative proposals from tax writers and other members and stirred up the debate about...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

French 3 Per Cent Tax on Distributions: French Subsidiaries of Foreign Companies Should Consider Claiming a Refund

Scope of The 3 Per Cent Tax - The 3 per cent tax is levied on dividend distributions and/or deemed dividend distributions by French companies, French permanent establishments and other French entities that are liable...more

Doing Business in Latin America and The Caribbean: Uruguay

With a geographical area of 176,215 square kilometers and a current population of 3.2 million inhabitants, Uruguay is one of the smallest countries in South America. Its current growth is 5% per annum. The Uruguayan...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

Doing Business in Latin America and the Caribbean: Puerto Rico

In 1493, Christopher Columbus arrived in Puerto Rico and claimed the island for the Spanish Crown. Spain controlled the island for most of the next four centuries until 1898, when it ceded Puerto Rico to the United States as...more

Doing Business in Latin America and the Caribbean: Peru

Peru is located on the central western coast of South America. Peru’s population is around 26 million people, with 52% of them living in the coastal region, 37% in the Andes and 11% in the Amazon region. Peru has a...more

Doing Business in Latin America and the Caribbean: Paraguay

With an area of 406,752 square kilometers, Paraguay occupies the central plain of South America. It has the world’s largest fresh water reserve known as “Acuífero Guaraní.” The country’s fertile soil is one of the major...more

Doing Business in Latin America and The Caribbean: Panama

Panama is the southernmost country of Central America. It has a total landmass of 75,517 square kilometers and an estimated population of 3,510,045 as of a July 2011. Its government is a constitutional democracy and the...more

Doing Business in Latin America and the Caribbean: Nicaragua

Nicaragua is the largest republic in Central America with the lowest population density. The country is bordered on the north by Honduras and on the south by Costa Rica. Its western coastline is on the Pacific Ocean, while...more

Doing Business in Latin America and the Caribbean: Mexico

With a total landmass of almost two million square kilometers, Mexico is slightly less than three times the size of Texas and has a total population of over 106 million people. Its political organization is a federal republic...more

Doing Business in Latin America and the Caribbean: Honduras

Honduras, in the north-central part of Central America, has a Caribbean as well as a Pacific coastline. Generally mountainous, fertile plateaus, river valleys and narrow coastal plains mark the country. With 112,090 square...more

Doing Business in Latin America and The Caribbean: Guatemala

Guatemala borders the Pacific and Atlantic Oceans, as well as Mexico, Belize, El Salvador and Honduras. It has a population of approximately 14.7 million people. Its form of government is republican, democratic and...more

Doing Business in Latin America and The Caribbean: El Salvador

With a territory of 21,000 square kilometers, El Salvador is the smallest country in Central America and the only one with no access to the Atlantic Coast. Its population reaches almost 7 million and the territory is...more

Doing Business in Latin America and The Caribbean: Ecuador

Situated on the northwest coast of South America, the Republic of Ecuador encompasses an area of approximately 256,549 square kilometers, or 99,438 square miles. Ecuador is a constitutional, democratic, sovereign and...more

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