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New Extra-Territorial UK Corporate Criminal Offence of Failing to Prevent Tax Evasion

by Goodwin on

A new corporate criminal offence of failing to prevent the facilitation of tax evasion takes effect on 30 September 2017. Corporates in both the UK and abroad will incur strict liability if their employees or other associated...more

Draft Legislation Published on UK Partnership Taxation

by Goodwin on

Earlier this year, HM Revenue & Customs published various ideas to ‘clarify’ the tax treatment of partners in partnerships, as part of its response to a consultation on changes to the taxation of UK partnerships. Draft...more

VAT In the UAE - What Your Business Needs to Do

by Bracewell LLP on

The UAE will introduce value added tax (“VAT”) at the rate of 5% from 1 January 2018. The basic principle underpinning the introduction of VAT is to further improve the economic base of the UAE. This is a significant...more

UK Enacts New Offences of Corporate Facilitation of Tax Evasion

The Criminal Finances Act 2017 (the Act) will enter into force in the UK on September 30, 2017, creating new corporate criminal offences in respect of the facilitation of tax evasion. Adopting the same approach as the offence...more

New guidance to register as “privileged” domestic or foreign investment fund under German investment taxation law

by Dechert LLP on

Pursuant to the new German investment tax act (GITA) that will take effect of 1 January 2018, domestic and foreign resident investment funds may become subject to German corporate income tax with various German source income...more

Disallowance of Deduction for Interest Paid to Hungarian Affiliate Serves as a Reminder of Department’s Continued Audit Scrutiny...

by Reed Smith on

A case recently resolved at the Appellate Tax Board serves as a reminder that Massachusetts’ auditors continue to aggressively challenge the following intercompany transactions: - Interest deductions for interest paid to...more

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

Corporate Tax Residence: Another Chapter

Another Case on Corporate Tax Residence: Why Does It Matter? - Corporate tax residence is an area of enduring enquiry and focus for HM Revenue & Customs (HMRC) in the UK. Development Securities (No.9) vs. HMRC [2017]...more

Morocco publishes new procedures for Advance Pricing Agreements

by DLA Piper on

Morocco has published Ministerial Decree No 2.16.571 outlining the procedure for concluding advance pricing agreements (APAs) with the Moroccan tax authority....more

Funds Talk: September 2017 - Tax Court Declines to Follow Rev. Rul. 91-32

In a recent decision, Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, the U.S. Tax Court declined to follow Revenue Ruling 91-32, and held that gain on the sale of an interest in an operating...more

Failure to Prevent the Facilitation of Tax Evasion: New United Kingdom Corporate Criminal Offence

by Proskauer - Tax Talks on

As mentioned in our July 2017 edition of UK Tax Round Up, the UK has enacted a new corporate criminal offence of failing to prevent the facilitation of tax evasion. The law comes into effect on 30th September 2017, and...more

Day 21 of One Month to More Effective Continuous Improvement-Code of Conduct

by Thomas Fox on

Continuous improvement also requires you to consider the backbone of your compliance program, your written Code of Conduct, policies and procedures. Under Prong 9, in the Department of Justice’s Evaluation of Corporate...more

Gross Receipts From Sales of Exported Goods Not Subject To Virginia BPOL Taxes

by Williams Mullen on

On August 24, 2017, the Supreme Court of Virginia issued a tax ruling that is favorable to Virginia taxpayers with international exports. As background, Virginia localities are permitted to impose the Business, Professional...more

UK Tax Round Up - August 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more

Tax Court Holds That Foreign Corporation’s Sale Of A Partnership Interest Not Taxable In US

by Cole Schotz on

The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more

AFRICA - A Legal Guide for Business Investment and Expansion: Zimbabwe

1 .What role does the government of Zimbabwe play in approving and regulating foreign direct investment? The Government established the Zimbabwe Investment Authority (ZIA) to promote, coordinate and approve investment...more

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

by Mintz Levin on

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

U.S. Withholding on Synthetic Trades over U.S. Equities—Further Delay of Full Implementation Until 2019 (Notice 2017-42)

In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more

Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits

by Dorsey & Whitney LLP on

Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tunisia

1. What role does the government of Tunisia play in approving and regulating foreign direct investment? The Tunisian government places a priority on attracting foreign direct investment. The Tunisian government...more

U.S. Tax Court Ruling Exempts Gain on Foreign Partner's Sale of a Partnership Interest

by Foley & Lardner LLP on

On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more

Developments in the U.S. Tax Treatment of UK Charities

by DLA Piper on

The Internal Revenue Service has revoked the U.S. tax exempt status of 195 prominent UK charities by posting their names on a website. These UK charities will find it harder to attract support from U.S. individuals and...more

Ireland's Revenue releases guidelines on requesting Mutual Agreement Procedure assistance

by DLA Piper on

Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tanzania

1 .What role does the government of the United Republic of Tanzania play in approving and regulating foreign direct investment? The government plays an active role in approving and regulating foreign direct investment....more

Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest

by McDermott Will & Emery on

In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more

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