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

Public Mergers and Acquisitions in Canada 2nd Edition - May 2017

by Bennett Jones LLP on

Canadian public merger and acquisition transactions in 2016 (in-bound and out-bound) comprised over C$400 billion in value with at least one-third of the transactions in Canada being fueled by foreign buyers. The second...more

Key Takeaways: Prospects for US Business Tax Reform — What You Need to Know

On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

RESTRUCTURING A MULTINATIONAL CORPORATION TO OPTIMIZE EFFICIENCY AND PROFITABILITY

by Owen Kurtin on

Attached is a free, downloadable case study (with diagrams) on the strategic, legal, tax and regulatory aspects of the implementation of a "Swiss Principal" model global restructuring for a U.S.-based industrial and...more

U.S.-India Newsletter - Vol. 2016, Issue 3

by Pepper Hamilton LLP on

Summer 2016 was a season of change. In Europe, we saw the "Brexit," with the United Kingdom voting to withdraw from the European Union. The June referendum sent shockwaves through the business and finance communities and...more

Recent Changes to the India-Mauritius Tax Treaty: What Does This Mean for American Investors?

by Pepper Hamilton LLP on

The amendments may cause some uncertainty and anxiety for U.S. investors as they consider how these changes will impact business, income, profitability and the benefits or drawbacks of investing in India through Mauritius....more

Your daily dose of financial news - The Brief – 8.30.16

by Robins Kaplan LLP on

And after all the sturm und drang surrounding the Hershey Trust and the Mondelez buyout offer over these past few months . . .  it’s over.  Mondelez announced yesterday that it’s no longer seeking to acquire the Hershey...more

OECD BEPS Working Groups issue three discussion drafts

by DLA Piper on

The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released three documents: its proposed updated guidelines on the application of the transactional profit split, draft...more

Brexit Update: What’s Next for the Global Marketplace

by McDermott Will & Emery on

In Depth - UK Withdrawal Process - The United Kingdom will continue to be an EU member until procedures are completed for exiting the European Union, which is likely to be a long process. Under EU Treaty rules,...more

Brexit: Tax Implications

by Morrison & Foerster LLP on

The majority has spoken: on Friday 24 June, it was announced that the UK had voted to leave the European Union (the “EU”). The full implications of this decision are largely unknown, given that the UK is navigating...more

Private equity in Italy: market and regulatory overview

by Latham & Watkins LLP on

How do private equity funds typically obtain their funding? Private equity funds continued to have a diverse investor base in 2015. Although with a significant decrease from the 2014 figure of 68%, about 48% of the...more

New "Inversion" Proposed Regulations Inspired By The Pfizer/Allergan Deal May Impact Corporate Tax Planning Strategies

by Baker Donelson on

The Treasury Department has recently promulgated proposed regulations dealing with so-called inversion transactions. Inversion transactions are ones in which a U.S. corporation changes its domicile to a nation with a more...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

by Latham & Watkins LLP on

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

PowerPoint Slides: Webinar on Recent Trends and Developments Affecting the IT Services and E-Commerce Sector Between the U.S. and...

by Pepper Hamilton LLP on

Leading law firms Pepper Hamilton and Khaitan & Co. joined together on this webinar to discuss: • Start-Up India - India’s newly adopted regime for start-ups and what it means for foreign investors and IT and e-commerce...more

Video: Webinar on Recent Trends and Developments Affecting the IT Services and E-Commerce Sector Between the U.S. and India [Video]

by Pepper Hamilton LLP on

Leading law firms Pepper Hamilton and Khaitan & Co. joined together on this webinar to discuss: • Start-Up India - India’s newly adopted regime for start-ups and what it means for foreign investors and IT and e-commerce...more

International Tax Advisory: New Temporary Regulations Continue the Fight Against Inversions

by Alston & Bird on

On April 4, the Treasury released temporary regulations to attack (and prevent) inversions. Aimed at transactions designed to avoid the purposes of Sections 7874 and 367 and certain post-inversion avoidance transactions, the...more

Alert: Treasury Department Expands Anti-Inversion Rules, Earnings Stripping Rules

by Cooley LLP on

On April 4, 2016, the United States Department of the Treasury issued temporary regulations that expand the scope of transactions subject to the rules designed to eliminate the US tax benefits of "inversions." The temporary...more

Treasury Department Issues Temporary and Proposed Regulations to Curb Inversions and Earnings Stripping

by White & Case LLP on

On April 4, 2016, the Internal Revenue Service and the Treasury Department issued temporary and proposed regulations formalizing rules contained in Notices 2014-52 and 2015-79 limiting corporate tax inversions, as well as...more

Expanded Earnings Stripping Proposed Rules Will Impact Typical Debt Push Downs

In a surprising move amidst its continuing crack down on corporate inversions, the U.S. Treasury just proposed new regulations reflecting a broadly expanded approach to the practice of earnings stripping. Because an inversion...more

M&A Update: Broad Anti-Inversion Rules Released

On April 4, 2016, Treasury released new rules making it more difficult for some U.S. companies to invert (“Serial Inversion Regulations”), Proposed Regulations limiting the effectiveness of “earnings stripping” techniques...more

The Pepper Minute: Corporate Inversions [Video]

by Pepper Hamilton LLP on

An inversion may offer significant tax benefits. In this short video, Pepper partner Howard Goldberg shares his thoughts on inversions - why undertake an inversion and the tax law addressing inversion transactions....more

New Tax Conditions for Foreign Investment in Australia - Treasurer to Impose Tax Conditions on all Foreign Investment Applications...

by K&L Gates LLP on

On 22 February 2016, the Hon Scott Morrison MP, Treasurer of the Commonwealth of Australia, published a media release regarding new requirements for foreign investment applications to ensure foreign companies investing in...more

European M+A News, Winter 2016

by Morrison & Foerster LLP on

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

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

by Thomas Fox on

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

International Tax Advisory: New IRS Notice Continues Attack on Inversions

by Alston & Bird on

There is no love lost between the U.S. Treasury and U.S. companies seeking offshore tax homes. Absent congressional action to stem the inversion tide, the Treasury and IRS are left to flex their regulatory and administrative...more

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