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International Tax News - August 2014

UKRAINE: NEW ANTI-CRISIS TAX MEASURES - The Verkhovna Rada, Ukraine’s Supreme Council, has approved amendments to the country’s tax law. Among the changes are amendments affecting the corporate profit tax and excise...more

No UK corporation tax deduction for penalty imposed under the code of the Fédération Internationale de l'Automobile ("FIA")

In an appeal by HMRC against a decision of the First-tier Tribunal ("FTT"), the Upper Tribunal (Tax and Chancery Chamber) ("UT") decided that a penalty imposed on McLaren Racing Limited ("McLaren") in respect of a breach of...more

How Windstream Ruling Will Affect Foreign Taxpayers

In general, a REIT is a special purpose entity for U.S. federal income tax purposes that requires at least 75 percent of the value of the entity’s gross assets to consist of real estate assets, cash, cash items, and...more

U.S. Tax Developments Affecting Financial Institutions and Products

Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more

International Tax News - July 2014

BITCOIN FORGES AHEAD: 3 QUICK LOOKS - Bitcoin is a decentralized peer-to-peer payment system that exists virtually and is unlimited by the constraints of countries, government or time. In an age when business leaps...more

The U.S. Tax Code: Love It, Leave It, Or Reform It!

On July 22, 2014, the Senate Finance Committee held a hearing titled, “The U.S. Tax Code: Love It, Leave It, or Reform It!” The general topic of the hearing was international taxation, with a sharp focus on recent and...more

Time For a New Home?

The high number of companies, mostly U.S., eyeing acquisitions or ventures that will allow them to redomicile their business in the UK and Ireland is a major theme of this report. Mostly, it is about tax. But there is quite a...more

Stay Ahead Of The Curve When Choosing Desired Tax Treatment

A foreigner starting business in the U.S. usually hires attorneys for visas, leases and licenses. The tax advisor comes later, when returns loom. This tendency is unfortunate because entering the U.S. starts the clock for...more

International Tax News - March 2014

NETHERLANDS: TAX TREATMENT OF HYBRID FINANCE INSTRUMENTS IN THE WAKE OF TWO LANDMARK CASES - The Dutch Supreme Court has given its judgment in two landmark cases regarding the classification of hybrid finance...more

Businesses Face More Onerous Transfer Pricing Documentation and Country-by-Country Tax Reporting

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a...more

Camp unveils major tax reform plan

Yesterday, House Ways and Means Committee Chairman Dave Camp (R-Michigan) unveiled his comprehensive tax reform proposal. Released as draft legislation, the Camp proposal calls for the most fundamental reform of the tax code...more

International Tax News - January 2014

WHEN THE PARTIES WANT AN AGREEMENT TO DISAPPEAR: THE US TAX RESCISSION DOCTRINE - The old saw about the best-laid plans of mice and men also goes for international tax planning and transactions with significant tax...more

Domestic double taxation relief applicable to capital gains derived by EU resident entities on disposal of shares in Spanish...

Following the non-discrimination principle, in response to an appeal dated 25 Octobe the Spanish Supreme Court has applied a tax credit to avoid double taxation, provided in the Corporate Income Tax Law for Spanish resident...more

Senate Finance Committee Chairman Releases Tax Reform Staff Discussion Drafts – More Expected

From November 19 through 22, 2013, Senator Max Baucus, Chairman of the Senate Finance Committee (the "Committee"), released three staff discussion drafts that propose sweeping changes to the federal rules regarding...more

Senate Finance Committee Chairman Baucus Releases Staff Discussion Draft to Substantially Reform the U.S. International Tax System

Last week U.S. Senate Finance Committee Chairman Max Baucus (D-Montana) released a staff discussion draft (the “Discussion Draft”) of proposals that, if enacted, would dramatically change the U.S. international tax system....more

Doing Business in Japan

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

Seeking a consensus around comprehensive tax reform: the latest developments in Congress

Amid the intense dispute over federal spending and debt, the chairmen of the tax writing committees in the US Senate and the House of Representatives continue their efforts to build a consensus among their members for tax...more

International Tax News - September 2013

FRANCE ANNOUNCES DRAFT 2014 BUDGET – LIGHTER TAX BURDEN FOR BUSINESSES - France’s draft budget law for 2014 was presented to Parliament on September 25 and is now under discussion in the National Assembly and...more

International Tax & Transfer Pricing Strategies in the Crosshairs

The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more

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