Tax International Trade

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Proposed Sec. 367 Regs Say Goodbye to Goodwill Exception

Citing aggressive taxpayer positions, recently proposed regulations do away with the foreign goodwill exception to gain or income recognition for outbound transfers under Section 367. The rules also restrict the type of...more

Mexico 2016 Tax Reform

The 2016 Tax Bill presented by the President to Congress on September 8, 2015 was approved almost in its original terms by both Chambers of Congress on October 29, 2015 and published in the Official Gazette of the Federation...more

IRS Announces Intent to Tax Transfers to Partnerships With Foreign Partners

On August 6, 2015, the IRS issued Notice 2015-54, which states that the IRS and Treasury intend to issue regulations under section 721(c) of the Internal Revenue Code to ensure that, when a U.S. person transfers certain...more

What's Your Audit Risk? It Depends!

Taxpayers who are considering one of the Streamline Procedures (Non-resident or Resident) have been advised by the IRS that their returns are subject to the regular audit selection process even though they must identify their...more

IRS Issues More Anti-Inversion Rules

Following on its prior Notice 2014-52 anti-inversion guidance, the IRS has issued new Notice 2015-79 to further limit (i) inversion transactions that are contrary to the purposes of the Section 7874 anti-inversion rules and...more

Supreme Court of Canada to Hear Tax Rectification Case

On November 19, 2015, the Supreme Court of Canada granted leave to appeal in Canada (A.G.) v. Groupe Jean Coutu (PJC) inc., 2015 QCCA 838, which addresses the question of when rectification will be granted in the tax context....more

M&A Update: Treasury Announces Second Anti-Inversion Notice

On November 19, 2015, Treasury issued Notice 2015-79 (the “Notice”), which announces Treasury’s intent to issue regulations reducing the tax benefits available to inverted groups and making it more difficult for some U.S....more

Global Tax News - November 2015

HANDS OFF DIGITAL CURRENCIES! CANADA’S SENATE CALLS FOR A LIGHT REGULATORY APPROACH Formerly considered a gimmick for geeks and gamers, digital currencies, such as Bitcoin, have grown into a worldwide phenomenon...more

HMRC Responds to Landmark Case on UK Tax Treatment of Delaware LLCs

Business as usual for UK taxpayers following Supreme Court decision in Anson v HMRC? HM Revenue and Customs (HMRC) has published its response to the UK Supreme Court’s decision in the landmark double taxation case of...more

How to Get in on the Offshore Fund Flow to the U.S.

A recent report estimates that foreign investors are expected to spend more than $70 billion on U.S. commercial real estate in 2015. Another report states that nearly a quarter of all recent commercial real property sales in...more

Cross-Border Charitable Activities

The Canada-US treaty provides significant relief for cross-border charitable activities. The treaty, and the competent authority agreement that implements it, says that a religious, scientific, educational, or charitable...more

Luxembourg rated as "Largely Compliant" by the OECD Global Forum

On 30 October 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary peer review report for Luxembourg....more

Proposed Regulations Nix Foreign Goodwill Exception to Tax on Outbound Transfers

The IRS and Treasury recently issued proposed regulations under Section 367 with bad news for taxpayers. Citing aggressive taxpayer positions, the proposed rules do away with the foreign goodwill exception and restrict the...more

The Gap, the Trap and the Binding Spring - The Bri-Chem trilogy, the rule of law and self-corrections of revenue-neutral tariff...

In three decisions released concurrently by the Canadian International Trade Tribunal (CITT) on September 18, 2015 (collectively referred to as the Bri-Chem trilogy), the CITT instructed the Canada Border Services Agency...more

Canadian International Trade Tribunal Declares CBSA Abusive and Directs CBSA to Follow its Decisions

On September 18, 2015, the Canadian International Trade Tribunal (CITT) released three decisions concurrently (collectively referred to as the Bri-Chem trilogy) that instruct the Canada Border Services Agency (CBSA) to apply...more

European Competition Law Newsletter – November 2015

A company that helps with or facilitates a cartel is at just as much risk of sanctions and penalties as are the actual cartelists. This was confirmed by the EU’s highest court (the European Court of Justice (ECJ)) on 22...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Latest Fund Statistics for Luxembourg Illustrate Continued Growth - ALFI has issued the fund statistics as of 30 September 2015. Luxembourg continues to be the number one location for Funds in Europe, with both number of...more

BEPS and real estate investment funds: What are sponsors to do?

The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the "Reports") after a two-year consultation period during which 62 countries and many other stakeholders (such as...more

The Common Reporting Standards - New Global Tax Information Exchange Regime Begins January 2016

The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January...more

OECD/G20 Base Erosion and Profit Shifting Project — Final Reports Released

On October 5, 2015, the Organisation for Economic Co-operation and Development (“OECD”) published final reports outlining the “actions” to be undertaken by OECD members as part of the base erosion and profit shifting (“BEPS”)...more

Consultation over Fixed Cap on UK Tax Deductibility of Corporate Interest Expense: Plucking the Feather in the Cap?

The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax...more

Trade & Manufacturing - News of Note - November 2015

GSP Program Review Results in Changes to Covered Products and Countries - In late September, the Office of the United States Trade Representative announced the outcome of the Generalized System of Preferences (GSP)...more

US China Trade War — TPP, Three False Trade Arguments, China President Trip, Trade, Customs, IP/Patent Securities

As indicated in more detail below, the Import Alliance will have meetings on November 17th and 18th in Washington DC. On the afternoon of November 17th, we will meet in our Washington DC office and then on November 18th meet...more

Abolition of Luxembourg IP Box Regime

On 14 October 2015, the Luxembourg Minister of Finance presented a bill to Parliament on the state budget for 2016. This bill contains several proposals affecting corporate taxpayers. One of the main proposals is the...more

Tax Haven List Repealed by D.C. Council

After being in effect for only a week, the Council of the District of Columbia (Council) unanimously enacted legislation on November 3, 2015 that will repeal the list of tax haven jurisdictions specifically enumerated in the...more

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