Tax Provisions in Business Acquisition Agreements
Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders
What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions
Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
WHAT ROLE WILL THE GOVERNMENT OF MALAYSIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
Regulation of foreign investment in Malaysia is done both through legislation as well as governmental policies....more
We are proud to present the next edition of our “Tax Review” which contains a selection of rulings and interpretations that had been issued or published in July 2015. We hope you will find the information provided here...more
On 4 August 2015, the governments of Cyprus and Iran signed an agreement for the avoidance of double taxation (the Treaty). With the lifting of international sanctions against Iran, Cyprus is now uniquely positioned to act as...more
WHAT ROLE WILL THE GOVERNMENT OF KOREA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
The Korean government takes an active, investor-friendly role in approving and regulating foreign direct investment....more
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
WHAT ROLE WILL THE GOVERNMENT OF JAPAN PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
Generally speaking, foreigners can conduct business in Japan on an equal legal footing with Japanese citizens. The...more
Court Of Appeals Affirms Revocation Of Tax Exemption For Public Parking Facilities -
Reversing a decision by the Appellate Division, the Court of Appeals has held in a 5-2 decision that a charitable organization is not...more
On 7 August 2015 the President of Ukraine has signed the Law ?609-VIII "On Amendments to the Tax Code of Ukraine (in respect of transfer pricing)" (the Law), which was previously adopted by Ukrainian parliament. The Law...more
The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event.
On August 6, the US Treasury...more
The tax arena in both China and Hong Kong has been a buzz since the last issue of our Tax Newsletter. In this edition, we draw your attention to certain recent developments that may carry legal and tax implications for your...more
A highway-funding bill passed by the Senate on July 30, 2015, and signed by President Obama on July 31st, contained certain tax provisions that change the due date of tax returns for many businesses. The bill, H.R. 3236,...more
The Stunning Altera Case -
Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more
Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House.
A Unanimous Decision -
A sequence of events led to the creation of 65 controversial vetoes...more
On April 30, 2015, Bill 12: the Common Business Number Act (the “Act”) came into force in Alberta. The Act created the authority for Alberta to adopt the Canada Revenue Agency’s (“CRA”) Business Number system (“BN”). The BN...more
In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more
On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect...more
The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015.
The Draft Bill contains significant changes to the German tax...more
The IRS published a list of Information Exchange agreements it has with state agencies, a copy of which is available here IRS State Information Exchange Table.pdf
The disclosure of this list may help taxpayer's and...more
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
We are proud to present the next edition of our “Tax Review” which contains a selection of rulings and interpretations that had been issued or published in June 2015. We hope you will find the information provided here...more
What the new horizontal tax consolidation regime may mean for private equity sponsors, multinational groups, financial institutions (and everyone else…).
In June 2014, the European Court of Justice (ECJ) ruled that the...more
On July 9, 2015, an expert panel convened by the Ontario Ministry of Government and Consumer Services (MGCS) released their final report (the Expert Report) containing many broad recommendations on how to modernize Ontario’s...more
EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB
The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more
Effective for tax years beginning on or after January 1, 2015, pursuant to legislation enacted last year, income from "investment capital" is exempt from New York State franchise tax for corporate taxpayers otherwise subject...more
On July 6, the Internal Revenue Service (IRS) Large Business and International Division issued a Directive1 to IRS agents regarding how to determine when a major component pertaining to steam or electric generation property...more
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