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New IP Legislation Under Consideration Regarding Tax Relief for Income Generated From IP Assets

McGraw Hill Financial, Oracle and Facebook, announced they are forming a group called “American Innovation Matters” (AIM) to lobby Congress to revise the U.S. international tax code rules in an effort to encourage innovation...more

New Japanese ECommerce Consumption Tax Commences Effect on October 1, 2015

On October 1, 2015, Japan commences application of its business-to-consumer (“B2C”) ecommerce consumption tax (“JCT”), analogous to the EU electronic services VAT which commenced January 1 of this year. The JCT will require...more

Use of Estonia in U.S. International Tax Planning

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

WTO Members Agree to Expand Scope of Information Technology Agreement

On July 24, the World Trade Organization (WTO) announced that 54 WTO members had reached a tentative agreement to expand the scope of the Information Technology Agreement (ITA) by adding 201 products, including new-generation...more

WTO Members Agree to Cut Tariffs on IT Products

On Friday, July 24, 2015, the World Trade Organization (WTO) announced that more than 50 of its member countries had agreed to cut tariffs on hundreds of information technology (IT) products, including semiconductors, MRI...more

The Upcoming Implementation of the Italian Patent Box Regime

Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more

Eliminating Tariffs on Information Technology (IT) Products: Expanded WTO List on the Horizon

On July 24, 2015 the World Trade Organization (WTO) announced that negotiators had agreed on a list of products and draft declaration to expand the product scope of the 1996 Information Technology Agreement (ITA). The...more

CRA: Bitcoins may be Specified Foreign Property

The CRA recently provided its views on whether digital currency, including Bitcoins, are considered “specified foreign property” under the foreign property reporting rules in section 233.3 of the Income Tax Act. Under...more

Alert: Is an Innovation Box Coming to the US?

United States lawmakers are facing increasing pressure from technology and life science industry leaders to adopt an "innovation box" regime to level the playing field with foreign counterparts and prevent significant US job...more

Dubai launches new design and e-commerce hubs

A cornerstone of Dubai's success in attracting businesses and encouraging growth across a diverse range of sectors has been the continued establishment of free zones. These special economic zones offer business-friendly...more

Japan makes significant changes to Consumption Tax Act – steps for offshore e-commerce providers

Japan’s National Diet has passed an amendment to the Consumption Tax Act which includes several important changes that especially affect offshore providers of e-commerce services in Japan. Change in cross-border...more

OECD Discussion Draft on Cost Contribution Arrangements vs. US tax rules on Cost Sharing Arrangements: key comparisons

The OECD has released a Discussion Draft on Cost Contribution Arrangements (CCAs) as part of its ongoing activities related to eliminating Base Erosion and Profit Shifting (BEPS) by multinational enterprises. This...more

Tax: Tax Considerations for Technology Licenses

The parties to licenses of technology should consider tax issues with such licenses. The following is a summary of some of the tax implications that may arise with regard to technology licenses....more

Reed Smith's Government Contracts Weekly Rundown - April 2015 #4

Here is a rundown of last week’s top developments related to government contracts to get you back on track and ready for this week....more

Bitcoin and the Like: Tax Considerations

Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or...more

Japan: Significant Changes In Consumption Tax

Raise in Consumption Tax Rate Postponed - On November 18, 2014, Shinzo Abe, the Japanese Prime Minister, officially announced that the increase of the consumption tax rate which was originally planned to occur in October...more

IRS Focus: Offshore Tax Evasion Tops Dirty Dozen List

The IRS issued two New Releases this week that restate its focus on offshore tax evasion. The first was January 29, 2015 which followed the First International Criminal Tax Symposium....more

National Security: Removing Barriers to Intra-Governmental Sharing of Information

The House of Commons in Canada is back in session. The federal Conservative Government wasted no time in introducing sweeping anti-terrorism bill (Bill C-51, the Anti-terrorism Act, 2015). I canvassed the legislative and...more

CBP Designates Preferred Ports of Entry for First-Time Canadian TN and L-1 Applicants

U.S. Customs and Border Protection (CBP) is the agency charged with overseeing and facilitating international travel and trade across the borders of the United States. The CBP’s mandate includes responsibility over...more

"Insights Conversations: Life Sciences"

A healthy market for M&A activity, particularly cross-border deals, and a strict regulatory environment are the big factors influencing the health and activities of life sciences companies. Skadden partners John T....more

The World Wide Tax Web: FATCA Data Sharing Goes Online

The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to...more

Australian Tax Alert: Bitcoin And Crypto-Currencies: Why The GST Law Should Change

The ATO released a draft ruling on the GST treatment of bitcoin transactions on 20 August 2014. A final version of that ruling, GSTR 2014/3, was released on 17 December 2014. While the ruling deals specifically with bitcoin,...more

Currency Conversion Concerns: New York Issues Guidance on Virtual Currencies

On December 5, 2014, the New York Department of Taxation and Finance (Department) released TSB-M-14(5)C, (7)I, (17)S. This (relatively short) bulletin sets forth the treatment of convertible virtual currency for sales,...more

U.S. Department of Commerce Announces Final Tariffs on Chinese and Taiwanese Solar Products

On December 17, 2014, the U.S. Department of Commerce (DOC) announced its final determinations in the antidumping duty (AD) and countervailing duty (CVD) investigations of crystalline silicon photovoltaic products (“solar...more

Spotlight On Federal Tax Developments In 2014

This article highlights a number of interesting federal tax developments that were brought to the table during the 2014 calendar year. Developments discussed in this article include the 18-month transitional period for the...more

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