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Withholding Tax Set to Increase

The Foreign Investment in Real Property Tax Act (FIRPTA) subjects foreign sellers to U.S. tax when they sell their interest in real property located in the U.S., including interests in companies that predominately hold real...more

IRS Revokes Ruling That Imposed Excise Tax On Wholly Foreign Reinsurance Transactions

The Internal Revenue Service recently revoked a 2008 ruling that a 1% excise tax under section 4371(3) of the Internal Revenue Code applied to “reinsurance premiums paid by one foreign insurer or reinsurer to another.” The...more

EU Customs Developments: December 2015

EU Customs Policy - Union Customs Code Developments – Key Provisions Published - On 29 December 2015, the Implementing and Delegated Acts for the Union Customs Code (UCC) were published in the EU’s Official Journal...more

Draft law: Russian VAT on software license transactions and e-commerce services

On 24 December 2015 a draft law was brought before the State Duma introducing important changes to the VAT taxation of software supply transactions and IT services ('Draft Law'). VAT on e-commerce services supplied to...more

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs. ...more

The Delaware Competes Act Signed Into Law

This week, Delaware Governor Jack Markell signed into law HB 235, otherwise known as the Delaware Competes Act of 2016. HB 235 was passed by the Delaware State House of Representatives on January 14, 2016 and the Delaware...more

Disclose of Cash Real Estate Purchases

The purchase of real estate without bank financing presents an opportunity for those with unclean funds to launder those funds and make them appear legitimate, at least in the opinion of the Financial Crimes Enforcement...more

RF Supreme Court Judges deny review of Oriflame Cosmetics by the Judicial Panel for Economic Disputes

RF Supreme Court Ruling No. 305-K?15-11546 of 14.01.2016 denied the transfer of the cassation appeal by OOO Oriflame Cosmetics against adverse judgments to the Judicial Panel for Economic Disputes for consideration in a court...more

New Rules on Investment Promotion in Azerbaijan

On 18 January 2016 the President of the Republic of Azerbaijan signed a Decree On additional measures in connection with the promotion of investments....more

Annulment of the European Commission´s decision regarding the former "Spanish tax lease structure" - EU General Court Decision:...

Background - On December 17, 2015 the EU General Court of Justice (EUGC) pronounced on appeals of joined matters T-515/13 Kingdom of Spain vs Commission and T-719/13 Lico Leasing, S.A., E.F.C. and Pequeños y Medianos...more

IP, IT and mass communications. Major Russian Legislation Changes for 2015 - Our traditional overview of the most important...

New songs on the main - Most of 2015 was spent anticipating the entry into force of RF Federal Law ? 242-FZ dated 21.07.2014 “On the Amendment of Certain Legislative Acts of the Russian Federation Clarifying the...more

Caution: Not All Iran Sanctions Were Terminated

U.S. persons, including permanent resident aliens and dual nationals should note that the Lifting of U.S. Sanctions on Iran under the Joint Comprehensive Plan of Action does not lift all sanctions....more

Energy Newsletter - January 2016

On 12 December 2015, nearly 200 countries reached an agreement that many have described as a historic turning point for global cooperation in addressing climate change. This article looks at the key elements of the Paris...more

Your daily dose of financial news The Brief – 1.14.16

So much for 2 days of optimism. Stocks took another dive yesterday, well into correction territory – NYTimes... Care to guess what that meant in Asia today (and Europe, for that matter)? – WSJ... Goldman Sachs is...more

FCPA Compliance and Ethics Report-Episode 224-Mat Kelly and Radical Compliance [Video]

In this episode I visit with former Compliance Week Editor Matt Kelly on his new venture, Radical Compliance. We geek out on Dodd-Frank, SOX, auditing, revenue recognition as they all relate to compliance. ...more

Evidentiary Problems with Threat of Injury Findings in Canadian Trade Remedy Cases

The recent proliferation of affirmative threat of injury findings by the Canadian International Trade Tribunal (CITT) indicates problems with the CITT’s approach to its threat of injury analyses. The CITT is arguably applying...more

TTB Publishes Projected Regulatory Agenda as Part of Government’s Unified Agenda

As it does twice per year, the Alcohol and Tobacco Tax and Trade Bureau (TTB) recently published its projected Regulatory Agenda as part of the federal government’s “Unified Agenda.” Links to the U.S. Department of...more

Protecting Americans from Tax Hikes Act Makes Substantial Changes to Tax Law

The Protecting Americans from Tax Hikes Act of 2015 (PATH Act) was signed into law on Dec. 18, 2015, as part of the Consolidated Appropriations Act, 2016. The PATH Act alters the regime for taxing foreign persons holding U.S....more

Financial Services Quarterly Report - Fourth Quarter 2015: Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

New Tax Law Includes Numerous Changes to REIT and FIRPTA Rules

On December 18, 2015, President Obama signed into law the “Protecting Americans from Tax Hikes Act of 2015” (the “Act”), a substantial piece of tax legislation that, among many other provisions, contains significant changes...more

Tax Newsletter - September/October 2015 (China & Hong Kong)

Welcome to the latest issue of our Tax Newsletter. A number of developments have taken place in the PRC and Hong Kong that could be of legal and tax significance to your businesses. In the PRC, the State...more

The Oman Update - Official Gazette 1127

Ministerial Decisions - Ministry of Commerce & Industry - Ministerial Decision No. 315/2015 Giving Effect to the Implementing Regulations of the GCC Unified Law of Anti-dumping, Countervailing Measures &...more

Tax Update: Tax Ruling Transparency in the EU - What You Need to Know

In the wake of the final OECD BEPS reports issued in October, the European Council adopted amendments to Directive 2011/16/EU providing for the automatic exchange of information concerning advance cross border rulings (ACBR)...more

Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

IRS Restructuring LB&I Division and Audit Process Again - Tax Update Vol. 2015, Issue 4

The changes include a move toward more issue-focused and efficient audits, which should benefit both the IRS and its taxpayers. It seems like the Internal Revenue Service (IRS) reorganizes its Large Business and...more

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