News & Analysis as of

Double Taxation

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

The UK Double Tax Treaty Passport Scheme – Changes for the UK Loan Market

by Morrison & Foerster LLP on

The UK Double Tax Treaty Passport (“DTTP”) scheme has recently been extended by HM Revenue & Customs (“HMRC”) to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme. The aim of the amendments is...more

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Tax Round Up - May 2017

by Proskauer Rose LLP on

Budget and Finance Bill - General Election – Finance Bill (No.2) 2017 Curtailed - The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more

Development of court practice of determining direct capital investment for the purpose of applying the 5% withholding tax rate...

by Dentons on

On 3 May 2017 the Commercial Court of Chelyabinsk Region rendered a decision in case No. ?76-20508/2016 under the claim of Chelyabenergosbyt PJSC (the “Company”)....more

2017 budget impacts for innovation and technology

by DLA Piper on

From a Government which had promised much in the way of innovation, the 2017 Budget is both underwhelming and, in one respect, potentially concerning. In terms of 'in' words, 'infrastructure' is very much in; 'innovation'...more

Extensions to the double tax treaty passport scheme

by DLA Piper on

The double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under...more

Prepared for the Border Adjustment Tax? A U.S. and Global Perspective

by K&L Gates LLP on

K&L Gates' Global Tax Group has been monitoring the potential impact of the Border Adjustment Tax (BAT) across a number of jurisdictions. In our 14 February 2017 update, we commented that issues regarding the legality of...more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Equity Incentives Update - Spring 2017

by DLA Piper on

Welcome to issue 1 of our Equity Incentives Update, dedicated to keeping companies informed about legal and regulatory developments affecting share-based incentives. In this issue we cover... Please see full...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Tax Planning in Uncertain Times

by McNair Law Firm, P.A. on

There is a long list of reforms that the Trump administration intends to tackle and one of the items on the list is tax reform. Although there are multiple proposals by various players and significant variations among the...more

House Proposal for Border Adjustability and Relevant WTO Rules

by Hogan Lovells on

On June 24, 2016, on behalf of the House Republican Caucus, House Speaker Paul Ryan, R -Wis., and House Ways and Means Chairman Kevin Brady, R -Tx., proposed sweeping reforms of the U .S. income and corporate taxes. The...more

BEPS: Update on Action 6 on Treaty Benefits

by Proskauer - Tax Talks on

In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and...more

Russia: tax law changes as of 2017

by White & Case LLP on

On 1 January 2017, a number of amendments to the Russian tax law entered into force. Below we highlight the key amendments applicable to the taxation of businesses in the following areas: 1. Corporate profit tax 2....more

2016 Native American Tax Litigation Roundup

One driver of economic development for many tribes is derived from their ability to impose taxes on business activities on Reservations free from state and local taxation. This year, there has been continued litigation to...more

Application of the concept of the person beneficially entitled to (beneficial owner of) income

by Dentons on

Dentons’ Russia Tax practice would like to remind that, starting from 1 January 2017, the procedure for confirming entitlement to tax benefits under relevant double tax treaties when paying income to foreign companies from...more

When Investing In A Partnership May Be A Tax Problem

by Farrell Fritz, P.C. on

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

India Amends Capital Gains Tax Treaty With Singapore

by Perkins Coie on

The Government of India amended its double taxation avoidance agreement (DTAA) with Singapore on December 30, 2016. The amendment allows the Government of India to levy source-based capital gains taxes on foreign direct...more

India and Cyprus Enter into New Tax Treaty

by Morgan Lewis on

On November 18, India and Cyprus signed a revised agreement for the avoidance of double taxation and prevention of fiscal evasion. Per a November 18 press release issued by the Indian government, the revised agreement...more

BEPS: OECD Releases Multilateral Tax Treaty Convention

by Proskauer - Tax Talks on

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more

"Double Trouble": The Kenyan Constitution and DTAs

by Dentons on

Controversy stalks international corporate taxation. With the integration of national economies and the promotion of Foreign Development Investments (FDIs), international corporations’ presence in multiple jurisdictions with...more

Where Did All The "S" Corporations Come From?

by Burr & Forman on

You just formed your medical practice in Alabama, and you either chose a professional corporation (a "PC") or an LLC. If you went with a PC, you get to choose between an "S" corporation ("S corp") or a "C" corporation ("C...more

Tax Tribunal Strikes Down Limitation on Credit for Taxes Paid to Other States

Readers may recall that Alabama Act 2012-427 permitted Alabama residents that owned interests in multistate pass-through entities (e.g., LLCs, partnerships, and S corporations) to claim a credit against their Alabama income...more

U.S.-India Newsletter - Vol. 2016, Issue 3

by Pepper Hamilton LLP on

Summer 2016 was a season of change. In Europe, we saw the "Brexit," with the United Kingdom voting to withdraw from the European Union. The June referendum sent shockwaves through the business and finance communities and...more

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