Tax Law, Commercial Law & Contracts, International Law & Trade

Did Sergio Garcia Lose in Match Play with the IRS?

by Thomas Wechter | Duane Morris LLP on 5/17/2013

One of the most recognizable names in professional golf—although not the most winning name, having never won a major golf tournament—is Sergio Garcia. He is especially known for his tree shots, the latest of which was a...more

Budget 2013-14: The Government targets multinationals to recover from the GFC - Baker & McKenzie

by Dixon Hearder, Amrit MacIntyre, John Walker | Baker & McKenzie Australia on 5/15/2013

The Treasurer has delivered the 2013-14 Budget. With the Treasurer noting that almost $170 billion has been wiped off tax receipts since the GFC, a series of measures increasing the tax burden of multinationals, foreign...more

UAE Launches New Financial Free Zone in Abu Dhabi

by Natalie Boyd, Amr Jaghoub, Simon Mabin | K&L Gates LLP on 5/9/2013

The federal government of the United Arab Emirates (“UAE”) has issued legislation establishing a new financial free zone in Abu Dhabi. The name of the new free zone, “Global Marketplace Abu Dhabi” (“GMAD”), serves as a...more

Franchising in Spain: 2012 in Review

by Antonio Viñal on 5/9/2013

With Madrid's annual franchise fair just around the corner, now is a good time to analyze what 2012 was like for the franchise sector in Spain. A solid performance overall, especially strong for Spanish franchises abroad....more

CFPB Finalizes Revisions to Remittances Rule, Sets October 28 Effective Date

by Alan S. Kaplinsky, Jeremy T. Rosenblum, Mercedes Kelley Tunstall | Ballard Spahr LLP on 5/8/2013

The Consumer Financial Protection Bureau has finalized revisions to its remittance transfers rule and set October 28, 2013, as the rule’s new effective date. While not entirely eliminating the requirement for remittance...more

Integrating Foreign Currency Hedges With Respect To Stock Purchase And Sale Agreements

by Steven Bortnick | Pepper Hamilton LLP on 5/7/2013

Investment funds that invest globally must deal with volatility in the currency in which they agree to invest. Investment funds entering into obligations to purchase stock in a currency other than the primary currency of the...more

U.S. to Cut Automotive Tariffs as Japan Enters TPP Talks

by Christopher Swift | Foley & Lardner LLP on 5/6/2013

On April 24, 2013, Acting U.S. Trade Representative (“USTR”) Demetrios Marantis formally notified Congress that the United States plans to include Japan in Trans-Pacific Partnership (“TTP”) negotiations. Coming just three...more

BVI, Cayman in discussions with UK government

by Peter Tarn | Harney Westwood & Riegels on 5/6/2013

The British Virgin Islands and the Cayman Islands are currently in dialog with the UK government on a number of issues related to the UK’s G8 economic agenda, including enhanced transparency and exchange of information for...more

Tax Talk -- Volume 6, No. 1 -- April 2013

by David de Ruig, Stephen Feldman, David Goett, Thomas Humphreys, Meimay Law, Anna T. Pinedo, Remmelt Reigersman | Morrison & Foerster - State + Local Tax... on 4/30/2013

In This Issue: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives and Modify Certain Other Tax Rules; After Months of Anticipation, Final FATCA Regulations Released; Congress Considers...more

Private Equity - Winter/Spring 2013

by Gus Black, Carl de Brito, Daniel Dunn, Thomas Friedmann, Richard Horowitz, Jeffrey M. Katz, Steven Lorch, Roger Mulvihill, Kenneth Wang, Paul Wang, Amy Yang, Scott M. Zimmerman | Dechert LLP on 4/29/2013

In This Issue: - ILPA Guidelines Have Noticeable Impact - Extracting Tax Value in Debt Refinancings and Modifications - Private Equity and Venture Capital Investing in China: Exit Strategy and Circular 698 -...more

Canadian Online Business Take Note: Internet Tax Case

by Field Law on 4/25/2013

“The world has changed dramatically in the last two decades… An entity may now have a profound impact upon a foreign jurisdiction solely through its virtual projection via the Internet.” ...more

EU Rejects Suspension of Auctions of EU Allowances; California Air Resources Board Formally Approves Linkage with Quebec

by Eric E. Freedman, Mariah Kennedy, Fiona Melville | K&L Gates LLP on 4/25/2013

On April 16, 2013 the members of the European Parliament voted 334-315 against the proposal of the European Union (EU) Commission to suspend future auctions of EU emission trading scheme (EU ETS) allowances until 2019 in...more

Proposed Legislation Would Sweep Certain Offshore Corporations into the U.S. Tax Net and Subject Their Worldwide Income to U.S....

by Dennis Allen, Robert S. Chase II, Jeffrey Mace, Michael Miles, William Pauls, M. Kristan Rizzolo, Carol Tello, P. Bruce Wright | Sutherland Asbill & Brennan LLP on 4/25/2013

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

Independent Contractor or Employee: Are Independent Contractors the Best Solution for Multinational Organizations?

by Carson G. Burnham, Bonnie Pucket | Ogletree, Deakins, Nash, Smoak & Stewart,... on 4/24/2013

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

Taxpayer Challenges Validity of IRS Transfer Pricing Regulation

by Steven Hannes | McDermott Will & Emery on 4/19/2013

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

Legal Alert: New Budget Proposals Once Again Target Insurance Companies

by Dennis Allen, Thomas A. Gick, Saren Goldner, Jeffrey Mace, Michael Miles, William Pauls, M. Kristan Rizzolo, Christopher Schoen, Linda Sciuto, W. Mark Smith, William Walderman, more +P. Bruce Wright | Sutherland Asbill & Brennan LLP on 4/16/2013

On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax proposals that target insurance companies or that otherwise would have a direct...more

Judicial Review Applications Challenging Minister’s Alleged Violation Of Voluntary Disclosure Policy And MAP Agreement Allowed To...

by David Spiro | Dentons on 4/15/2013

In Sifto Canada Corp. v. Minister of National Revenue, 2013 FC 214, Prothonotary Aalto of the Federal Court rejected the Crown’s motion to strike out judicial review applications filed by Sifto Canada Corp. challenging...more