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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

New Guidance Sheds More Light on Italian Carried Interest Tax

by McDermott Will & Emery on

Following the approval of the new rules regarding taxation of carried interest proceeds enacted with Law Decree No. 50/2017 (Decree), the Italian Tax Authorities issued specific guidelines with Circular Letter No. 25/E, dated...more

Do You Have a Foreign Trust?

The answer in the litigation context may not be black and white because it requires a careful, analytical walk through the applicable sections of the Internal Revenue Code, the appropriate regulations and the nonexclusive...more

End and refund of the French 3% tax on distributions

by White & Case LLP on

The French Constitutional Court rules that the 3% contribution on distributions is unconstitutional - On 6 October, 2017, the French Constitutional Court, in its decision (n°2017-660 QPC), held that the 3% contribution on...more

Treasury Would Overhaul 2016 Regulatory Guidance

by Alston & Bird on

With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and...more

Criminal Finances Act 2017 – New Criminal Offence Requires Preventive Procedures

by McDermott Will & Emery on

The UK Criminal Finances Act 2017 recently introduced a new corporate offence of failure to prevent the facilitation of tax evasion. Under the new law, a corporate body or partnership may be criminally liable if it fails...more

Checking The Box, Partnership Allocations, And Foreign Law

by Farrell Fritz, P.C. on

Many of our clients, most of which are closely-held U.S. businesses, are looking to expand their operations overseas. Some are venturing into foreign markets on their own, while others are joint-venturing with established...more

New GTO covers Wire Transfers

by Foodman CPAs & Advisors on

On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New...more

Window on Washington - This Week in the Nation's Capital - Vol. 1, Issue 30

by Clark Hill PLC on

House Passes Bill on Disaster Funding: House Republicans easily passed a supplemental spending bill that included $36.5 billion of disaster aid with a vote of 353-69 after some initial worries on Thursday afternoon that it...more

IRS Provides Relief for Bona Fide Residents of U.S. Virgin Islands, Puerto Rico

by Holland & Knight LLP on

• Because of the damage Hurricanes Irma and Maria inflicted on the U.S. Virgin Islands and Puerto Rico, the IRS has relaxed the stringent physical presence requirements that individuals typically must satisfy to qualify as...more

Financial Services Quarterly Report - Third Quarter 2017: Luxembourg Developments

by Dechert LLP on

Luxembourg recently has taken a number of actions in connection with the transposition or implementation of various EU directives and regulations, respectively, into national law. The Luxembourg government deposited a bill of...more

Información tributaria de 36 países ya está en Colombia

by Holland & Knight LLP on

Por medio del comunicado de prensa No. 149 del 9 de octubre, la DIAN informó que en desarrollo de los Acuerdos de Intercambio de Información vigentes y de la Ley FATCA, recibió la información correspondiente al año 2016, de...more

Financial Services Quarterly Report - Third Quarter 2017: Global Update: UK Criminal Finance Act 2017: Immediate Considerations...

by Dechert LLP on

UK asset managers, non-UK asset managers carrying on business in the UK and the funds they manage are within the scope of the new corporate criminal offences of failing to prevent the facilitation of tax evasion. As the new...more

TechConnect - Your Law Firm Link to Industry News - September 2017

by Mintz Levin on

Letter from the Editors - Words are very powerful and the language we use often frames a discussion. For example, the term “shareholder activist” sounds like a consumer friendly person who has everyone’s best interests at...more

Tax Court Denies Treaty Benefit To Canadian Post–Doctoral Fellow

by Fox Rothschild LLP on

In a case of first impression, the Tax Court held that the U.S.–Canada Tax Treaty (Treaty) did not exempt a Canadian citizen from U.S. income tax on the unemployment compensation she received from the State of Ohio. Pei Fang...more

M&A Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more

Minnesota Corporate Franchise Tax Change for Foreign Disregarded Entities

by Stinson Leonard Street on

The Minnesota Department of Revenue issued its position on foreign disregarded entities of corporate taxpayers on October 4, 2017. In response to the Minnesota Supreme Court decision filed August 2, 2017 in Ashland Inc. v....more

Treasury Hints That Regulatory Review May Target FATCA Regulations

by Fox Rothschild LLP on

In a report to the President recommending actions to eliminate or mitigate burdens imposed on taxpayers by eight specific tax regulations, the Treasury Department indicated that it is considering possible reforms of...more

September 2017: An Update on UK Tax Disputes Including the New UK Corporate Criminal Offense: What Is It and What Should You Do...

Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more

Anti-Inversion Regulations Held to Violate Administrative Procedure Act

by King & Spalding on

On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more

UK Criminal Finances Act 2017 Commences with New Tax Evasion Offences, Anti-Money Laundering Rules, and Asset Forfeiture...

On 30 September 2017, Part 3 of the UK Criminal Finances Act 2017 (the “CF Act”) came into force creating new corporate offences for failing to prevent the facilitation of UK or overseas tax evasion. Similar to the standard...more

Amazon and Apple Issued Rulings from the European Commission

by King & Spalding on

The EC concludes that Luxembourg provided illegal tax benefits to Amazon of €250 million and refers Ireland to the European Court for failure to recover illegal tax benefits from Apple of €13 billion - On 4 October 2017,...more

What’s New in Washington: 10 Things You Need to Know

Congress returned after Labor Day for a busy September and acted quickly to avoid a government shutdown by passing stop gap funding for Fiscal Year (FY) 2018 and raising the debt ceiling. The already crowded congressional...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Uber’s Board of Directors has officially voted to realign the power balance at the company, reducing the clout of ousted CEO Travis Kalanick, and setting the stage for a stock sale to SoftBank. Oh yeah, and prepping for that...more

Treasury To Repeal/Revise 8 Burdensome Regs

As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more

Court Revisits FBAR Willfulness Requirement and Concludes Taxpayer Is Not Willful

In a recent decision, the United States District Court for the Eastern District of Pennsylvania reexamined the requirements for willful failure to file a TD F 90-22.1, the predecessor to the current FinCEN Form 114, Report of...more

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