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IRS Publishes Proposed Regulations for Hedge Fund Reinsurance Arrangements

In April 24’s Federal Register, the IRS released proposed regulations (REG-108214-15) to restrict when a foreign insurance company’s income can be excluded as passive income by giving a more strict definition for the “active...more

FCPA Compliance and Ethics Report-Episode 154-Compliance Leadership-Persuasion, Influence, Tools & Tips, Skills and Tips [Video]

In this episode, I discuss some of the tools which a compliance practitioner or CCO can use to further compliance in an organization. ...more

U.S. Companies with Foreign Affiliates Face Looming Reporting Deadline

U.S. companies with material ownership interests in foreign affiliates (including their own subsidiaries) are facing an upcoming May 29, 2015 deadline to file a cumbersome survey with the U.S. Department of Commerce...more

Tax Planning for International Transportation Income

According to the most recent estimates, the quantity of goods carried by containers has risen from around 100 million metric tons in 1980 to about 1.5 billion metric tons in 2012. Out of these numbers, one container in every...more

Skechers, Cost Sharing Arrangements, and Canadian Customs Appraisal

In the first three months of 2015, importers have witnessed major Canadian customs valuation law and policy changes. On January 19, 2015, the Canada Border Services Agency (CBSA) issued Customs Notice 15-001, “Treatment of...more

Bad News About Unfiled FBARs, Another Indictment

A recent indictment by the United States Attorney's office in California illustrates the inter-relationship between curency transfer restrictions, (such as those involving Iran), foreign financial account reporting (the FBAR...more

Treasury and the IRS Offer a New Take on the PFIC Active Insurance Exception

On April 23, Treasury and the IRS issued proposed regulations interpreting the active insurance exception under the passive foreign investment company (PFIC) rules. Although the release of the proposed regulations did not...more

FBAR Case Rules on Unknown Issues

A recent FBAR decision weighs in on some unknown and uncertain penalty issues relating to failure to file FBARs. These issues include...more

CBSA CLVS Seizure Policy Targets Exporters and Ups the Ante on Non-Resident Importers

Background to the Courier Low Value Shipment (CLVS) Program - When goods are purchased through e-commerce or mail order, conventionally Canadian consumers or non-resident importers (i.e., the exporters in most cases)...more

Swiss Bank Settlements-What's Next for U.S. Taxpayer's?

The Department of Justice has released the signed Non-Prosecution Agreement NPA) with Swiss bank BSI SA. The Non-Prosecution Agreement is likely the precursor to enhanced enforcement efforts by the DOJ and IRS against those...more

Guinea: New Hydrocarbons Code

The Guinean State Minister of Mines and Geology, Kerfalla Yansané, recently announced a possible launch of a bidding round in 2015 for offshore oil blocks in Guinea under the new hydrocarbons code (the “New Code”). Following...more

Increased Activity Seen Under the California Transparency in Supply Chains Act Is Your Company Prepared?

In April 2015, the California Department of Justice began, for the first time, to send letters to companies regarding compliance with the California Transparency in Supply Chains Act. The Act, effective January 1, 2012,...more

Focus on Private Equity - April 2015

In This Issue: - The Use of Alternative Credit in Europe - Buying and Selling a Craft Brewery in the United States - Excerpt from The Use of Alternative Credit in Europe: As a result of the reduced...more

The Intersection of the FCPA, TI-CPI and Tax Appeals in Brazil

The Transparency International-Corruptions Perceptions Index (TI-CPI) is released each year in November. The TI-CPI rates Brazil as 69th out of 175 countries on its index, coming in with a score of 43 out of 100. I wonder if...more

California AG Asks Retailers And Manufacturers To Report On Supply Chains Act Compliance

The California Attorney General’s office recently sent letters to retailers and manufacturers asking them to demonstrate compliance with the California Transparency in Supply Chains Act or why they are not subject to the act....more

GST may be extended to intangible supplies

The Federal Treasurer, Joe Hockey, commented at a Press Conference and Q&A session following the Council of Federal Financial Relations Meeting in Canberra on 9 April 2015 that the States & Territories have agreed in...more

International News: Focus on International Private Client

In This Issue: Features - ..The UK Response to BEPS and Hybrid Mismatches ..Parental Liability for French Subsidiaries ..The Evolving US-Cuba Trade Landscape ..Amendments to Taiwan Fair...more

A Guide to the UK Disguised Investment Management Fee Rules

New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...more

Developments in the Luxembourg Financial Sector

The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), has recently issued FAQs regarding the immobilisation of bearer shares and units, as well as a press release to remind...more

Global Tax News - March 2015

Australia's Investment Management Regime reforms 30 MAR 2015 - Australia’s Investment Management Regime (IMR) reforms, initially proposed by the Australian Financial Centre Forum in the Johnson Report in 2009 and the...more

European Competition Law Newsletter – April 2015

On 19 March 2015, the European Court of Justice (ECJ) handed down a significant judgment on the application of EU competition law to information exchange between competitors. ...more

QFIIs/RQFIIs - Implications of Retrospective Capital Gains Tax

At a compliance seminar held last month, officials from the Asset Management Association of China (AMAC) and the State Administration of Taxation (SAT) informed industry executives that Chinese regulators are planning to...more

Bitcoin and the Like: Tax Considerations

Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or...more

Potential refund of Swedish withholding tax: opportunity for US RICs

In 2012, the Swedish Administrative Court of Appeal concluded that Sweden’s withholding tax rules are not compatible with EC law when Swedish withholding tax is levied on dividend payments made to a Luxembourg SICAV fund. ...more

Luxleaks - Challenging the challenges to tax rulings in the EU

The European Commission's recent state aid crusade against so-called sweet deals in the form of tax rulings may have unwelcome consequences never contemplated by the Commission....more

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