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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

Stay Ahead Of The Curve When Choosing Desired Tax Treatment

A foreigner starting business in the U.S. usually hires attorneys for visas, leases and licenses. The tax advisor comes later, when returns loom. This tendency is unfortunate because entering the U.S. starts the clock for...more

Doing Business in Latin America and The Caribbean: Columbia

Colombia is located in the northernmost part of South America. Its population is estimated at over 45 million people, with at least 10 million living in the capital city of Bogotá. Colombia’s main language is...more

Doing Business in Latin America and The Caribbean: Cayman Islands

The Cayman Islands are located in the western Caribbean Sea about 480 miles south of Miami and 180 miles northwest of Jamaica. Of the three islands, Grand Cayman is the largest with an area of 76 square miles. The islands of...more

A SWISS PRINCIPAL MODEL CASE STUDY: RESTRUCTURING A MULTINATIONAL CORPORATION THROUGH TERRITORIAL OPTIMIZATION

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

Doing Business in Latin America and The Caribbean: The Bahamas

The Commonwealth of The Bahamas is an archipelago spanning 100,000 square miles extending southeast from Florida to northern Hispaniola. The Bahamas has an estimated land area of 5,382 square miles made up of 700 islands ...more

M&A Update: Treasury Department Proposes To Expand Anti-Inversion Rules

The Treasury Department, in its Fiscal Year 2015 Revenue Proposals (the “Green Book”), has proposed to significantly tighten Section 7874 of the Internal Revenue Code, effective January 1, 2015, reducing the ability of a U.S....more

The 3 Most Significant Tax Matters for Multinationals in 2014

What is the most significant tax consideration facing multinationals in 2014? That’s the question we recently put to leading tax advisors, asking for their quick take on the matter as we launch our new 'Need to Know' series....more

Borrower Beware: Loan Transactions can be a Taxable Event for U.S. Corporations that have Foreign Subsidiaries

A loan transaction is generally not thought of as resulting in a taxable event. But it can if the borrower is a U.S. corporation (U.S. Co.) with a foreign subsidiary (FS). More specifically, a loan transaction can trigger a...more

Successful Strategies For Doing Business In Asia: Thailand

1. What role does the government of Thailand play in approving and regulating foreign direct investment? The Thai government regulates foreign direct investment by requiring foreign investors to obtain approval from...more

Your Nonprofit Has Gone Global: Now What Are Your U.S. and Foreign Tax Compliance and Reporting Obligations?

In this presentation: - Form of foreign operations - Foreign tax treatment of the foreign operations - U.S. tax treatment of the foreign operations - VAT/GST issues - Employee and...more

Ten Offshore MLP Facts

Offshore MLPs can provide a tax efficient vehicle for investors, but only if structured properly. A master limited partnership (MLP) is a partnership or limited liability company traded on a stock exchange that...more

Editorial: How US Cos. Can Reduce Latin American Tax Obligations

Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted through wholly-owned foreign subsidiaries. Originally Published in Law360 - October 29,...more

Tax Talk -- Volume 6, No. 3 -- October 2013

In This Issue: A Primer on the Medical Device Excise Tax; FATCA Registration Begins; In re Downey Financial Corp. (U.S. Bankr. Court Dist. of Delaware 10/8/2013); In re NetBank (11th Cir. 9/10/2013); and In re...more

Tax Planning For U.S. Companies With Latin American Operations

Pass-through structures - Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries....more

Proposed Regulations On Imported Built-In Losses Include Some Controversial Aspects

Proposed Regulations (REG-161948-05, 9/6/13) dealing with the importation of built-in loss properties under Sections 334(b)(1)(B) and Section 362(e)(1) are designed "to prevent erosion of the corporate tax base through the...more

Top Labor and Employment Law Issues When Taking your Start-Up Global

Our colleague Ute Krudewagen has put together a list of some key labor and employment issues to consider if and when you decide to take your US-based emerging company to overseas locations. So you are ready to...more

Mixing Oil and Vinegar - Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the Investment Return of...

Overview - Master Limited Partnerships are publicly traded partnerships. As of 2010, the market capitalization of MLPs was $220 billion. These publicly traded partnerships invest primarily in energy and associated...more

CIS Legal Update - September 2013: Kazakhstan National ID Scheme and Issues for Foreign Executives

Six years after the passage of the Law of the Republic of Kazakhstan on National Registers of Identification Authorities (“National Registry Law”) of 12.01.2007 (as amended on 21.06.2013), on January 1, 2013, obtaining an...more

The 3M Case: Can the IRS Overrule the Supreme Court?

3M Company’s challenge to the validity of Treas. Reg. § 1.482-1(h)(2), if successful, could result in refunds for taxpayers that previously followed the Internal Revenue Service’s regulatory guidance purporting to overrule...more

Global Employment and Benefits Update - Issue 3 2013

In This Issue: - Proposed Changes to Partnership Tax Rules - An International Primer on Good Cause Dismissals - Settlement Agreements - In Profile: Euan Fergusson - News in Brief - Upcoming...more

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

AIFM Remuneration Code Guidance

Summary - The UK’s Financial Conduct Authority (“FCA”) has published draft guidance on the application of rules on remuneration (the “AIFMD Remuneration Rules”) to FCA-authorized firms, once they become authorized as...more

Massachusetts Rules Against Taxpayer on Treatment of Intercompany Debt—Again

In what is becoming a trend, the Massachusetts Appellate Tax Board (the "ATB") has issued yet another decision denying true debt treatment for an intercompany obligation. In National Grid Holdings, the ATB upheld assessments...more

Sweeping Changes to the Pennsylvania Tax Code - The Passage of Pa. House Bill 465

House Bill 465, also known as Act 52, was signed into law by Pennsylvania Governor Tom Corbett on July 9, 2013. The Bill makes substantial changes to the Pennsylvania tax code as an integral part of the 2013–2014 budget....more

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