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

ATO wins Full Federal Court decision on Cross Border Financing - Chevron Australia Holdings case

by DLA Piper on

In a major Australian transfer pricing decision on Friday 21 April 2017, the Full Federal Court dismissed Chevron Australia Holdings Pty Ltd's (CAHPL) appeal related to the deductibility of interest on the Australian dollar...more

Global Employee Equity at a glance: Spain

by White & Case LLP on

Stock Option Plans: Employment - Labor Concerns - Plan benefits are considered part of an employee's salary for the purposes of calculating entitlements on termination of employment. There is a risk that an...more

Extensions to the double tax treaty passport scheme

by DLA Piper on

The double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under...more

Global Employee Equity at a glance: United Arab Emirates

by White & Case LLP on

Stock Option Plans: Employment - Labor Concerns - There is a risk of employees claiming that they are entitled to compensation for loss of rights under the Plan where the Plan is amended or discontinued or where...more

Blog: Failure to Prevent Criminal Facilitation of Tax Evasion

by Cooley LLP on

The new UK “failure to prevent criminal facilitation of tax evasion” domestic and overseas offences will almost certainly become effective in or before September 2017. What does this mean for companies and firms? The offences...more

Global Employee Equity at a glance: United States of America

by White & Case LLP on

Stock Option Plans: Employment - Labor Concerns - There is a risk of employees claiming that they are entitled to compensation for loss of rights under the Plan where the Plan is amended or discontinued or where...more

Update on Domicile and Tax of Offshore Trusts

by McDermott Will & Emery on

Implementation of the 6 April 2017 tax changes applicable to non-domiciled individuals, offshore trusts and UK residential property has been delayed because of the forthcoming UK General Election on 8 June 2017. Whilst it is...more

IRS Updates FATCA FAQs, Addresses January Temporary Regulations

by Proskauer - Tax Talks on

On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online. These additional FAQs...more

Global Employee Equity at a glance: Taiwan

by White & Case LLP on

Stock Option Plans: Employment - Labor Concerns - There is a risk of employees claiming that they are entitled to compensation for loss of rights under the Plan where the Plan is amended or discontinued or where...more

Global Employee Equity at a glance: Turkey

by White & Case LLP on

Stock Option Plans: Employment - Labor Concerns - There is a risk of employees claiming that they are entitled to compensation for loss of rights under the Plan where the Plan is amended or discontinued or where...more

Global Employee Equity at a Glance: United Kingdom

by White & Case LLP on

Stock Option Plans: Employment - Labor Concerns - There is a risk of employees claiming that they are entitled to compensation for loss of rights under the Plan where the Plan is amended or discontinued or where...more

Debit cards, Offshore Funds and a John Doe Summons

by Foodman CPAs & Advisors on

IRS remains committed to its priority efforts to stop offshore tax evasion wherever it occurs. It pursues cases in all jurisdictions of the world. Over the years, numerous individuals have been identified as evading US...more

OTA & Travel Distribution Update - April 14th, 2017

by Garvey Schubert Barer on

This week’s OTA & Travel Distribution Update for the week ending April 14, 2017 is below. Additional details regarding last week’s long-awaited report on online travel by the European Commission are featured in this week’s...more

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

More Items Subject to Individuals’ Mandatory Tax Reporting in Kazakhstan

by Morgan Lewis on

On January 1, 2017, amendments affecting individual income tax reporting came into force in the Republic of Kazakhstan. Amendments to the Tax Code of the Republic of Kazakhstan (Tax Code) became effective January 1, expanding...more

Focus on Tax Strategies & Developments - April 2017

by McDermott Will & Emery on

Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more

China updates special tax adjustment measures: new rules go into effect May 1

by DLA Piper on

China's State Administration of Taxation (SAT) has released the Administrative Measures on Special Tax Investigation Adjustments and Mutual Agreement Procedures in the Public Notice [2017] No. 6 (Bulletin 6). Bulletin...more

Colombia criminaliza la evasión fiscal

by Foodman CPAs & Advisors on

El 12/29/2016, el Congreso de Colombia aprobó la "Ley 1819 de 2016". La nueva legislación es una reforma tributaria estructural encaminada principalmente a aumentar los ingresos para Colombia....more

Turning Tides

by DLA Piper on

Ukraine is typically seen as an emerging country, blighted by crisis. Ukrainians are all gradually helping to change this stereotype. Here we examine key legal reforms aimed at improving the efficiency and safety of...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

China’s infamous shadow banking industry—an $8.5 trillion marketplace that’s sprung up in reaction to the government’s “campaign against financial leverage”—is back and bigger than ever these days....more

The Cannabis Act: An overview

by Dentons on

On April 13, 2017, Canada’s Liberal government introduced Bill C-45, the Cannabis Act (the “Act”). The tabled legislation provides federal guidelines for legal access to cannabis for non-medical purposes and establishes...more

Dutch Supreme Court refers questions on withholding tax refunds for foreign investment funds to CJEU

by DLA Piper on

The Dutch Supreme Court has referred preliminary questions on Dutch dividend withholding tax refunds for foreign investment funds to the Court of Justice of the European Union (CJEU). The Dutch Supreme Court wishes to clarify...more

QDOT-ting I's and Crossing T's: Estate Tax Planning for Non-United States Citizen Spouses

by Ward and Smith, P.A. on

Individual and corporate citizens from countries around the world have moved to North Carolina and contributed materially to our state's economic, educational, and cultural growth. Foreign direct investment ("FDI") in North...more

Tax Court Déjà Vu – IRS Tried, and Failed, to Overturn Veritas

by Alston & Bird on

In a recent decision (Amazon Inc. v. Commissioner, March 23, 2017), the Tax Court handed the IRS an unsurprising loss when it attempted to relitigate many of the same issues it unsuccessfully raised before the Tax Court in...more

New Due Date for “FBAR” Filings - Report of Foreign Bank and Financial Accounts now due on Tax Day, with auto-extension for six...

Federal law requires U.S. citizens and resident aliens to report world-wide income, including income from foreign trusts, bank and securities accounts. In addition to attaching Schedule B to their tax returns disclosing...more

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