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Anti-Avoidance Tax Avoidance

Bennett Jones LLP

Income Tax Update from the Supreme Court of Canada: The GAAR Does Not Apply to Treaty Shopping

Bennett Jones LLP on

The Duke of Westminster Principle Still Lives On for Tax Planning - On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC...more

Proskauer Rose LLP

UK Tax Round Up - January 2021

Proskauer Rose LLP on

UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more

Hogan Lovells

Tech Tax – Looking Forward to 2020

Hogan Lovells on

Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more

Katten Muchin Rosenman LLP

New EU-Wide Tax Anti-Avoidance Law Introduces Sweeping Disclosure Requirements

Key Points - Coming into force on 1 July 2020, EU DAC6 Regulations will require intermediaries in certain cross-border arrangements to disclose activity to tax authorities. - The DAC will apply retroactively to affected...more

Proskauer - Tax Talks

Extended tax liabilities for directors in insolvencies linked to tax avoidance

Proskauer - Tax Talks on

Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise...more

Proskauer Rose LLP

UK Tax Round Up - May 2019

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UK General Tax Developments - HMRC updates guidance on what constitutes "ordinary share capital" - Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this...more

Womble Bond Dickinson

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

Womble Bond Dickinson on

Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more

Alston & Bird

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

Alston & Bird on

On April 2, in quick succession, the IRS and Treasury announced notices addressing two provisions added by the Tax Cuts and Jobs Act (TCJA): the repatriation tax under Section 965 and withholding on non-publicly traded...more

Alston & Bird

Treasury Issues Final Regulations Under Section 956

Alston & Bird on

On November 3, 2016, the Treasury issued final regulations (T.D. 9792) that set forth guidance on when a controlled foreign corporation (CFC) has a deemed repatriation under Section 956 in ...more

Proskauer - Tax Talks

EU Council Agrees on Final Anti Tax Avoidance Directive

Proskauer - Tax Talks on

We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

McDermott Will & Emery

Treasury and IRS Issue New Temporary Treasury Regulations

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more

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