AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
On July 13, 2022, the European Parliament and the European Council agreed on a new regulation concerning “foreign subsidiaries that distort the European market.” Their agreement is the final stage prior to voting on the...more
The European Commission (the "Commission") published a draft Directive on 22 December 2021, known as the anti-tax avoidance Directive III ("ATAD III"), aimed at preventing the use of shell companies for tax evasion and...more
The new Spanish Controlled Foreign Company rules might have a major impact on non-resident holding companies, and particularly those resident in a country outside the EU and the EEA due to the controversial (and, in our view,...more
On May 18, 2021, the European Commission (the Commission) of the European Union (the EU) published a communication on “Business Taxation for the 21st Century” (the Communication), setting out a long-term vision to provide a...more
UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more
The European Commission (the Commission) published on 2 April a summary of its findings on a state aid investigation into the United Kingdom’s controlled foreign company (CFC) finance company exemption. The Commission has...more
Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society in the world” by Wired magazine. According to recent figures, Estonian...more
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
We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more
Japan Signs Economic Partnership Agreement with EU - On July 17, 2018, Japan signed an Economic Partnership Agreement ("Japan-EU EPA") with the European Union ("EU"). Once the Japan-EU EPA is implemented, 99 percent of EU...more
A consultation paper on national security and investment published by the UK government advocates extensive changes to current provisions regarding foreign investment in UK businesses. In essence, the proposed changes would...more
On October 26, 2017, the European Commission (EC) announced a formal State aid investigation into a U.K. exemption from U.K. anti-tax avoidance rules for certain transactions by multinational groups, the so-called Group...more
The Background: The European Commission has opened an in-depth investigation into a specific provision of the UK-controlled foreign company rules. The Issue: The Commission will investigate whether the UK's so-called Group...more
On 5 December 2017, the Economic and Financial Affairs Council (ECOFIN) determined a list of 17 non-cooperative jurisdictions, which included Bahrain and the United Arab Emirates (UAE). This list was established based on...more
The EU State aid rules are designed to stop Governments and local authorities giving companies a selective advantage, as doing so would create an unequal playing field. Say for example, a competitor in one country was given a...more
EU opens investigation into UK tax scheme for multinationals - The EU State aid rules are designed to stop Governments and local authorities giving companies a selective advantage, as doing so would create an unequal...more
On 26 October 2017, the European Commission (the Commission) opened an in-depth investigation into UK statutory rules that exempt certain financing income earned by foreign subsidiaries of UK corporate taxpayers from UK tax....more
The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more
The June 23, 2016 “leave” Brexit vote has left many in the business and legal communities stunned, and while uncertainties abound, there is no doubt that wading through the economic and administrative complexities of exiting...more
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
On 21 June 2016, the EU Council reached agreement on the EU Anti Tax Avoidance Directive (“ATAD”). The ATAD is expected to be adopted in a forthcoming ECOFIN meeting, possibly on 12 July 2016. The Council had reached...more
The proposed Council Directive marks another, significant, though likely problematic, step towards tackling tax avoidance across Member States. Background - The European Commission (the Commission) has been moving...more
What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more
Agency Template for Tailored Resolution Plans - On September 3, the FDIC and the Fed released an optional model template for tailored resolution plans required to be submitted by the Dodd-Frank Act. SEC Risk...more