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CBSA Announces Mid-2014 Audit Targets

As is its practice, the Canada Border Services Agency recently announced its semi-annual trade verification targets for the balance of 2014. Many targets continue from the past, while new ones have been added....more

Introduction of the Exploration Development Incentive

In the 2014 Budget, the Federal Government announced that it would introduce Exploration Development Incentive (EDI) tax credits to encourage and stimulate growth in the junior mining industry. This is a simpler approach to...more

Department of Commerce Announces Preliminary Decision to Impose Tariff on Solar Panels Imported From China

Some U.S. solar equipment manufacturers have lauded the Department of Commerce’s recent decision to impose high tariffs on solar panels imported from China as the end of China’s unfair market advantage; however, from the...more

German Federal Government Plans Tax Exemption of INVEST – Subsidy for Venture Capital

The German Federal Government has given an important insight to its plans and future measures regarding taxation of the start-up- and VC-ecosystem in Germany by officially answer to a parliamentary request by several members...more

M&A Update | Inversions: The View from Ireland

On June 25, 2014, Ireland’s Taoiseach (Prime Minister) Enda Kenny and Minister for Finance Michael Noonan, among others, met with Cadwalader Chairman-elect and Corporate Group Co-Chair James C. Woolery in Dublin regarding...more

United States Prevails in WTO Dispute Challenging China's Duties on U.S. Automobiles

Last month, a World Trade Organization (WTO) Panel issued a report favorable to the United States, ruling against Chinese duties on American auto exports. China had imposed tariffs on U.S. cars and SUVs with engine capacities...more

Tax authorities updated their interpretation of certain transfer pricing issues

On 1 July 2014, the Ministry of Revenues and Levies of Ukraine has issued Order #368 "On amendment of Generalized tax consultation on transfer pricing related issues, adopted by the order #699" (hereinafter - the Order) which...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

The IBC Act – the building of a nation

Although nobody knew it at the time, the inception of the BVI’s International Business Company Act occurred at some point during the year 1976. Nobody now recalls the exact date, except that it was during the summer.It is...more

Japan To Reduce Corporate Income Tax Rate

The corporate income tax rate in Japan is known to be one of the highest worldwide. To encourage foreign companies to do business in Japan and make Japan a more attractive location for investments, Prime Minister Shinzo Abe...more

Orrick's Derivatives in Review - July 2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

International Tax News - June 2014

NEW FOR SUPPLIERS OF DIGITAL CONTENT AND INTANGIBLES: DLA PIPER’S GLOBAL VAT GUIDE - Starting January 1, 2015, EU VAT rules for suppliers of digital content, telecommunications and broadcasting services are changing....more

Affirmative Use of U.S. Partnerships in Inbound Tax Planning

A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC...more

European Commission probes into national tax rulings on transfer pricing

The European Commission (“EC”) has long sought to eliminate so-called harmful tax competition, which it sees as undermining the integrity of the internal market, fair competition and the fiscal sustainability of the Member...more

Intangible Services, Rights And Digital Content: Global VAT Guide

Welcome to DLA Piper’s Global VAT Guide: Cross Border Supplies of Intangible Services, Rights and Digital Content. As business grows more global, the challenge for in-house counsel and in-house VAT specialists is...more

Update on the EU's Proposed Financial Transactions Tax

The Court of Justice of the European Union (CJEU) recently issued a decision rejecting the UK government’s initial legal challenge against the proposed introduction of a financial transactions tax (FTT) in Europe. The...more

Sweden proposes new system for corporate taxation: a redistribution of tax payments in the business sector

A Swedish government committee mandated to analyze the Swedish corporate tax system - including the need for a more comprehensive approach to the overall deductibility of interest expenses, as well as the strengthening of the...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

IRS Issues Revenue Ruling on Applicability of Section 457A to Options and Stock Appreciation Rights

On June 10, 2014, the IRS issued Revenue Ruling 2014-18, which holds that nonqualified stock options, as well as stock-settled stock appreciation rights (SARs), do not constitute nonqualified deferred compensation subject to...more

IRS Ruling Allows Tax-Deferred Stock Rights for Fund Managers

Section 457A of the Internal Revenue Code (the Code) generally restricts the ability of offshore funds and other entities domiciled in tax-indifferent jurisdictions to offer tax-advantaged deferred compensation to U.S....more

Pre-Filing Consultation of SEC Staff Regarding Venezuela Operations May Be Appropriate in Certain Circumstances

In a recent meeting, a representative of the SEC accounting staff noted that the SEC staff is focusing on how companies with operations in Venezuela are affected by the various foreign currency exchange mechanisms in...more

Doing Business in Canada: Taxes & Duties

SALES AND TRANSFER TAXES: GOODS AND SERVICES TAX - Canada has a 5% value-added tax imposed on goods and services called the Goods and Services Tax (GST). The GST is applied to each transaction in the production and...more

Kazakhstan Amends Legislation to Improve the Investment Climate

The amendments offer an incentives package for new projects in industries of prime importance. The Law on Amendments to Certain Legislative Acts of the Republic of Kazakhstan to Improve the Investment Climate (the Law)...more

Abengoa Yield PLC Highlights From IPO

Abengoa Yield plc began trading on the NASDAQ on June 13th. The Form F-1 (the equivalent of a form S-1 for a foreign issuer) is available below. The IPO was priced at $29 a share. This was above the expected range of $25 to...more

Financial Regulatory Developments Focus - June #3

In this issue: - Compensation - Capital and Prudential Regulation - Bank Structure - Financial Services - Consumer Protection - Enforcement - People - Events...more

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