Double Taxation

News & Analysis as of

Amendments to real estate legislation - Quarter 1 of 2016

Amendments to federal laws - Federal Law No. 431-FZ dated 30 December 2015 “On Geodesics, Cartography and Spatial Data and on Amendments to Certain Legislative Acts of the Russian Federation” The law under...more

Development of the tax practice of the “beneficial owner” concept

On March 3, 2016 the Commercial Court of Moscow rendered a decision on case No. ?40-241361/15 (the “Decision”) under the claim of BANK INTEZA joint stock company (the “Russian Company”). The decision contains a number of...more

GST to be removed from Bitcoin transactions – how best to fix the "double taxing" of digital currency?

The Treasurer, Scott Morrison, recently announced that the Government is committed to working with the FinTech industry on legislative solutions for the GST "double tax" issues that can arise on domestic transactions...more

Group Seeks Relief For U.S. Citizens With RESP and TFSA Accounts

In a letter dated March 4, 2016, the American Chamber of Commerce in Canada (“AmCham Canada”) requested that the United States Department of the Treasury (“Treasury”) provide various forms of tax relief to U.S. and Canadian...more

UK Budget 2016: Finance

From April 2017, the UK government is to cap the amount of corporation tax relief for interest to 30% of taxable earnings in the UK or the net interest to earnings ratio for the worldwide group. This is subject to a threshold...more

European M+A News, Winter 2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

White & Case ECB News – Issue 2, 2015: 60 seconds around the globe – ECB News Issue 2, 2015

China - Changes to Employee contribution rates for work related injury insurance and maternity insurance - As of 1 October 2015, employer contribution rates for injury-at-work insurance and maternity insurance have...more

Kyiv Tax Alert (Ukrainian)

On 11 December 2015 the representatives of the governments of Ukraine and Cyprus have signed the Protocol on amending the Convention between the Government of Ukraine and the Government of Cyprus on the Avoidance of Double...more

Kyiv Tax Alert - Amendments to the Convention between the Government of Ukraine and the Government of Cyprus on the Avoidance of...

On 11 December 2015 the representatives of the governments of Ukraine and Cyprus have signed the Protocol on amending the Convention between the Government of Ukraine and the Government of Cyprus on the Avoidance of Double...more

International News: Focus on Tax - Issue 3, 2015

The breadth of the articles contained in our Focus on Tax this issue demonstrates the perennial importance of this topic to global businesses and international high net worth individuals. We examine topics ranging from...more

HMRC Responds to Landmark Case on UK Tax Treatment of Delaware LLCs

Business as usual for UK taxpayers following Supreme Court decision in Anson v HMRC? HM Revenue and Customs (HMRC) has published its response to the UK Supreme Court’s decision in the landmark double taxation case of...more

Australian Tax Update - October 2015

The Chevron decision provides critically important guidance on both the 'old' (Division 13) and 'new' (Subdivision 815-A) transfer pricing laws in Australia. While not dealing specifically with Subdivisions 815-B to D, the...more

Tax Newsletter - July/August 2015 (China & Hong Kong)

Welcome to the latest issue of our Tax Newsletter. As you may be aware, much has happened since our last issue. In this issue, we highlighted a number of developments in both the PRC and Hong Kong that could be of legal and...more

U.S. Supreme Court Vacates Decision in First Marblehead; Remands to Massachusetts Supreme Judicial Court

On October 13, the United States Supreme Court granted a request for review in the case of First Marblehead Corporation v. Massachusetts Commissioner of Revenue, and summarily vacated the decision issued January 28, 2015, by...more

Wynne’s First Casualty: First Marblehead Corp. v. Commissioner

Today, the U.S. Supreme Court vacated the decision of the Massachusetts Supreme Judicial Court (SJC) in First Marblehead Corp. v. Commissioner of Revenue (First Marblehead) and remanded the case back to the court for...more

Putting the Final BEPS Reports into Perspective: from Recommendations to Implementation

The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. ...more

Breaking News: U.S. Supreme Court Vacates Decision in First Marblehead; Remands to Massachusetts Supreme Judicial Court

Today, the United States Supreme Court granted a request for review in the case of First Marblehead Corporation v. Massachusetts Commissioner of Revenue, and summarily vacated the decision issued January 28, 2015, by the...more

Global Private Equity Newsletter - Fall 2015 Edition: The Summer Budget – Changes to the UK Tax Treatment of Carried Interest

The Chancellor of the Exchequer’s recent Summer Budget and the related legislation introduced a series of unexpected tax changes along with the promise of further changes to come. Shortly after the Summer Budget was issued...more

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

UK tax treatment of US LLC: HMRC’s practice following Anson

We reported earlier this year on the UK Supreme Court’s decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to claim relief against his UK tax liabilities for US tax paid on his share of...more

Australian Tax Alert: Double Taxation Agreement with Israel

Whilst Australia and Israel already share a close relationship, a DTA will serve to strengthen the economic ties between the countries. A DTA will provide greater tax certainty for business, enhance both countries' tax...more

"Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson"

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border...more

UK tax treatment of US LLCs: HMRC responds to the Supreme Court’s decision in Anson v HMRC

Executive Summary - Her Majesty’s Revenue & Customs (HMRC) has now published its response to the U.K. Supreme Court’s recent judgment in Anson v HMRC. The response confirms that HMRC will continue its existing practice...more

Work With Experienced Attorney To Navigate Tax Issues With Stock Sales

In our last post, we began speaking about the recent Tesla Motors stock sale announcement. As we noted, the company is hoping that the move will help expand its business presence, a task that has been somewhat challenging....more

Israeli Tax Authority Extends Deadline to Register Family Trusts and Elect Tax Regime

On June 29, 2015, the Israeli Tax Authority extended the deadline for registration of Family Trusts (sometimes referred to as Relatives Trusts), which are trusts created by a non-Israeli grantor for the benefit of one or more...more

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