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Treasury Proposes Fundamental New Limitations on Related Party Lending Transactions – With Retroactive Effect!

The U.S. Treasury Department has very recently and unexpectedly released significant guidance that promises, if finalized, to fundamentally limit the circumstances under which related corporations (and, in some cases,...more

Potential tax consequences of Brexit from a UK perspective

This alert considers the possible impact of Brexit on some key UK tax aspects. However, this is only one side of the perspective: we will shortly be publishing a second article considering the potential impact of Brexit on...more

New Rules Provide Relief from Canadian Withholding on Salary Paid to Cross-Border Employees

Proposed amendments to the Income Tax Act (Canada) (ITA) will provide relief from Canadian payroll withholdings for many non-resident employers whose employees work in Canada on a temporary or short-term basis....more

Update: Transfer Pricing and Customs Valuation Case Study Published on WCO Website

On 29 April 2016 the World Customs Organization (WCO) published the full text of a case study where Customs takes into account a company's transfer pricing study based on the transactional net margin method (TNMM) in...more

French 3% contribution tax on distributions: Claim opportunities for French subsidiaries of MNEs following new developments...

On April 6, 2016 the First Instance Court of Montreuil filed a request with the French Constitutional Court in relation to potential breaches of the French Constitution (more precisely the Declaration of Human Rights dated...more

Federal Budget Update

The Australian Government continued its attack on Multinational Tax Avoidance with the release of its 2016-2017 Federal Budget. Central to its Budget initiatives is the introduction of a 40% Diverted Profits Tax on large...more

Proposed Tariff Elimination for Certain Agri-Food Ingredients

In Budget 2016: Growing the Middle Class, the Government of Canada announced its intention to eliminate customs duties on imports of certain food manufacturing ingredients, excluding supply-managed (TRQ) products. This...more

IRS Rules Could Treat Related Party Debt as Stock

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

Update on The Panama Papers

The International Consortium of Investigative Journalists (ICIJ) announced that on May 9, it will release selected data purported to be leaked or stolen from the internal records of the Panamanian law firm Mossack Fonseca....more

WCO TCCV approves case study on TNMM transfer pricing documentation and customs valuation

During the week of 18-22 April 2016 the World Custom's Organizations Technical Committee on Customs Valuation (TCCV) held its 42nd Session in Brussels. At this session a new instrument was approved by the TCCV that contains a...more

The Panama Effect: UK Government accelerates proposals to criminalise failure to prevent tax evasion

10 considerations for professionals and corporates worldwide in advance of the new law. Overview - In a move widely seen as a response to the so-called “Panama Papers” revelations, the UK Government has enhanced...more

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

"FIRPTA Reform Impacts Investment Opportunities in US Real Estate"

In recent months, much has been written to describe the reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) contained in the Protecting Americans From Tax Hikes Act of 2015 (the Act), which have been...more

Latin American countries focus on new legislation around tax and transfer pricing – independence limitations in Ecuador

A recent report published by the United Nations’ Economic Commission for Latin America and the Caribbean (CEPAL) calculated that Latin American countries have lost more than US$98 billion in tax revenues simply due to...more

Amendments to real estate legislation - Quarter 1 of 2016

Amendments to federal laws - Federal Law No. 431-FZ dated 30 December 2015 “On Geodesics, Cartography and Spatial Data and on Amendments to Certain Legislative Acts of the Russian Federation” The law under...more

Tax Newsletter - January / February 2016 (China & Hong Kong)

Welcome to the latest issue of our Tax newsletter. In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. In the PRC,...more

As Panama Papers Illustrates, IRS Discovery of Undisclosed Assets Just a Matter of Time

As the recent leak of the "Panama Papers" reminded the world, some secrets don't keep well, particularly those related to undisclosed foreign assets. And once a person's identity is disclosed as a holder of undisclosed...more

China's Nationwide VAT Reform - Implementation Rules Issued

In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. In the PRC, there has been an important development in the past...more

Foreign Financial Asset Reporting - Coming Soon to a Domestic Entity Near You

When Form 8938 reporting for foreign financial assets of U.S. taxpayers was first imposed a few years, only U.S. individuals were subject to it. The IRS has now issued final regulations that will commence reporting by...more

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

PowerPoint Slides: Webinar on Recent Trends and Developments Affecting the IT Services and E-Commerce Sector Between the U.S. and...

Leading law firms Pepper Hamilton and Khaitan & Co. joined together on this webinar to discuss: • Start-Up India - India’s newly adopted regime for start-ups and what it means for foreign investors and IT and e-commerce...more

Video: Webinar on Recent Trends and Developments Affecting the IT Services and E-Commerce Sector Between the U.S. and India [Video]

Leading law firms Pepper Hamilton and Khaitan & Co. joined together on this webinar to discuss: • Start-Up India - India’s newly adopted regime for start-ups and what it means for foreign investors and IT and e-commerce...more

Your daily dose of financial news The Brief – 4.21.16

Dealbook’s White Collar Watch gives us a legal take on the many challenges, regulatory and otherwise, facing Elizabeth Holmes’ Theranos – NYTimes... The international financial scandal du jour (the Panama Papers) is...more

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