News & Analysis as of

Cross-Border Transactions Withholding Tax

A&O Shearman

FASTER: the European Commission’s proposal to improve withholding tax procedures

A&O Shearman on

The European Commission has released its much anticipated proposal on streamlining withholding tax procedures. The proposal for a Directive on the “Faster and Safer Relief of Excess Withholding Taxes” (or the “FASTER”...more

Goodwin

Public Consultation on a Common EU-Wide System for Withholding Tax Claims on Dividend and Interest Payment

Goodwin on

The EU Commission published a public consultation based on its initiative to introduce a common EU-wide system for withholding tax on dividend or interest payments, which includes a system for tax authorities to exchange...more

Dorsey & Whitney LLP

Plan Ahead to Reduce (or Eliminate) U.S. Withholding Tax when Selling or Transferring U.S. Subsidiaries holding U.S. Real Property

Dorsey & Whitney LLP on

Many Canadian companies and individuals own U.S. real property interests through a U.S. corporation. The Foreign Investment in Real Property Tax Act (“FIRPTA”) regime imposes a withholding tax (currently at a rate as high as...more

Morrison & Foerster LLP

German Registered IP: New Taxation Of Transactions Between Non-German Parties

In a decree published November 6, 2020, the German tax authorities confirmed their view that transactions between non-German parties (e.g., between two U.S. companies) are generally taxable in Germany, if this income is...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

White & Case LLP

European Real Estate Finance: Recent developments – June 2019

White & Case LLP on

As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more

Hogan Lovells

Budget 2017

Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

Dechert LLP

ECJ Ruling Opens Door To Withholding Tax Refunds

Dechert LLP on

The European Court of Justice (ECJ), in the case of Brisal, has determined on 13 July 2016 that national law which prohibits a non-resident taxpayer from deducting financing/operating costs from interest withholding tax...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

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