Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
On August 25, 2014, the Indiana Supreme Court issued its decision in Indiana Department of State Revenue v. Caterpillar, Inc., holding that the plain meaning of the Indiana tax statutes prohibited the company from increasing...more
Welcome to our redesigned Tax Newsletter.
You will notice we have streamlined the publication and will now publish bi-monthly instead of quarterly. For major developments that may be highly...more
Canada has a vibrant Internet community. Because of the great expansion of the Internet in Canadian homes and businesses, Canada and its provinces have, in recent years, regulated Internet activity and...more
The corporate income tax rate in Japan is known to be one of the highest worldwide. To encourage foreign companies to do business in Japan and make Japan a more attractive location for investments, Prime Minister Shinzo Abe...more
The amendments offer an incentives package for new projects in industries of prime importance.
The Law on Amendments to Certain Legislative Acts of the Republic of Kazakhstan to Improve the Investment Climate (the Law)...more
With a geographical area of 176,215 square kilometers and a current population of 3.2 million inhabitants, Uruguay is one of the smallest countries in South America. Its current growth is 5% per annum.
The Turks and Caicos Islands (TCI) lie 575 miles southeast of Miami and 39 miles southeast of The Bahamas. There are eight principal inhabited islands which have an estimated population of 35,000. The legal system is based...more
The European Court of Justice has issued a judgment concerning the authority of Poland to grant a corporate income tax (CIT) exemption to investment funds depending on where their registered offices are located.
All “modern” income tax treaties concluded by the United States contain a “Limitation on Benefits” (LOB) provision. The purpose of such a provision is to prevent “treaty shopping.” Romania is one of the few remaining...more
This year will mark a half-decade since the release of Circular 698. The confluence of local enforcement and increased exits by off-shore investors may make 2014 its most interesting year....more
The strategic geographical position of the country and the membership with the European Union provide a wide range of investment opportunities in Bulgaria not only for local, but for foreign investors as well. The advanced...more
I am pleased to present to you DLA Piper’s “Doing Business in Japan” Guide.
Japan is the world’s third largest economy and remains cutting-edge in business. In 2012, 68 Global 500 Companies were headquartered in...more
The China (Shanghai) Pilot Free Trade Zone (PFTZ) officially launched on September 29th, granting 25 Chinese and overseas companies licenses to register in the PFTZ on its first day. The General Plan for the PFTZ was...more
The IRS has released Private Letter Ruling 201322009, which responds to a request for clarification on the proper application of certain “look-through” rules for purposes of determining whether a foreign corporation is a...more
India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more
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