Read Tax Law news, alerts, and legal commentary from leading lawyers and law firms:
Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk
Hot Topics for Waste-to-Energy Investors and Developers
Monitor Thy Drink: Alcohol Import Regulations Under the TTB (Alcohol and Tobacco Tax and Trade Bureau)
Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More
The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate Insights
Will The Debt Ceiling Standoff End Up In Court?
Corporate Law Report - Office Party Holiday Risks, Human Trafficking, the Fiscal Cliff, More
Micah Green on U.S. Fiscal Policy
Corporate Law Report: Obamacare Deadlines, $13M for Exotic Dancer Misclassification, 2013 Medicare Taxes, More...
Tax Questions to Ask Yourself with the End of 2012 and the Fiscal Cliff Approaching
How Do We Pay For Lower Corp Tax Rates?
Polsinelli Shughart Election Analysis and Legal Insight
Why choose Bennett Jones for your Canadian Cross-Border Income Trust (CBIT)?
What are the tax benefits of a Canadian Cross-Border Income Trust (CBIT)?
Why choose Canada for a Cross-Border Income Trust (CBIT)?
What is a Canadian Cross-Border Income Trust (CBIT)?
Bill on Bankruptcy: Solyndra, Lehman, MF Global, ATP Oil, LSP Energy, Want Ads
Should you Opt-Out of the Voluntary Disclosure Program?
Weekly Brief: CFPB, Legal Fees & Hashtag Hijackers
Cost of Voluntry Asset Disclosure Program
When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because, it is legal. ...more
This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more
We've highlighted a few notable developments in corporate governance law taking place this spring that may be of interest to you. For more information on any of the topics listed below, please contact us at...more
Beginning on December 31, 2013, the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trusts (WT) will be subject to the requirements of a foreign financial institution (FFI). As a...more
The Stop Tax Haven Abuse Act and the International Tax Competitiveness Act of 2013 are two parts of a package of three bills introduced in the U.S. House of Representatives on April 15 by Rep. Lloyd Doggett. A significant...more
Almost every organization expanding overseas needs a vehicle to explore the market before making the business decision to establish a legal entity, yet few legal vehicles are available for this preliminary measure. Most...more
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
The Organisation for Economic Co-operation and Development (“OECD”) recently published a report in which the Cayman Islands was commended for the “streamlined, efficient and responsive procedures it has is in place to...more
International buyers invested $82.5 billion in U.S. residential real estate (4.8% of total U.S. sales) according to the most recent survey conducted by the National Association of Realtors for the 12 month period ending with...more
In a petition recently filed in the U.S. Tax Court, a taxpayer has challenged the Internal Revenue Service (IRS) regulation that provides that the IRS can reallocate income between affiliates even when foreign law prohibits...more
Disclosure: Joseph A. DiRuzzo, III of Fuerst Ittleman David & Joseph was part of the trial team that represented the taxpayers in the June 2010 bench trial in the District Court of the Virgin Islands....more
Cyprus has been in the spotlight recently due to the negotiations with what has become known as the troika (the International Monetary Fund, the European Central Bank and the European Commission)...more
Earlier this year, the United States District Court for the Middle District of Louisiana upheld the Internal Revenue Service’s disallowance of $1 billion of deductions claimed by Dow Chemical in relation to two transactions...more
To insulate the ultimate individual owners from U.S. estate taxes, nonresident aliens often hold U.S. real property in a U.S. corporation, which corporation is owned by a foreign corporation. The foreign corporation is owned...more
The Canada Revenue Agency had an important win this week in its efforts to access information outside of Canada. On March 20, 2013, the Federal Court issued its decision in Soft-Moc Inc. v. M.N.R. 2013 FC 291, dismissing...more
Every financial media outlet (including Bloomberg and the Wall Street Journal) in the last several weeks has run an article on the possibility of billionaire hedge fund manager becoming a Puerto Rican...more
Nonresidents are generally not subject to U.S. income taxes on their capital gains if present in the U.S. for less than 183 days in the tax year. Code Section 741 treats the gain from the sale or exchange of a partnership...more
On February 28, 2013, India’s Finance Minister presented the country’s budget for the fiscal year beginning April 1, 2013 (Budget). The Budget includes several proposals that affect international investors investing in India,...more
One of the most heated debates among Americans is whether to close the so-called corporate loopholes. However, there is wide misconception as to what exactly are “tax loopholes.” According to Eric Toder, co-director of the...more
Types de sociétés aux Emirats
Il existe 3 types de sociétés aux Emirats Arabes Unis:
Société? « Offshore »
Pour des activités exclusivement en dehors des Emirats (pas de client et de fournisseur, ni de bureau, ni de...more
Key changes affect the registration and re-registration of legal entities in Kazakhstan.
UK investors in closely held offshore funds can be directly liable for tax if the fund makes a gain on an underlying asset even if the gain is reinvested by the fund and not distributed to the investor. There is also the...more
An Indian tax appellate tribunal has recently ruled on the issue of marketing intangibles in a transfer pricing case involving the Indian manufacturing and sales subsidiary of the Korea-based LG Electronics Inc. In that case,...more
Watch our latest Corporate Law Report for:
- a speed round of need-to-know employment law advisories covering workplace secret recordings, the EEOC's strategic enforcement plan, the NLRB in Obama's second term, and more;
It has long been popular for high net-worth people who are not domiciled in the United Kingdom (“non-doms”) to form an offshore company, often in the British Virgin Islands (“BVI”), for the purposes of holding property in the...more
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