Double Taxation

News & Analysis as of

Florida Supreme Court: Origin Sourcing for Sales Tax is Constitutional

The Florida Supreme Court upheld the imposition of a sales tax obligation on an in-state florist for all of its worldwide sales regardless of delivery destination. This “origin sourcing” method of determining transactions...more

Florida Sales Taxes on Internet Sales Outside of Florida [Florida]

Question: A Florida corporation, with a physical location and principal address in Florida, sells flowers, gift baskets, and other items of tangible personal property over the Internet. The company does not maintain any...more

Global Tax News: India announces fundamental changes to the India-Mauritius double tax treaty

The Government of India announced in a press release dated May 10, 2016 that Mauritius and India have signed a protocol amending the agreement for avoidance of double taxation with Mauritius. The text of the protocol is...more

Investing in India? Take a Look at the Amended India-Mauritius Tax Treaty Before You Do

On May 10, 2016, India and Mauritius signed a protocol amending the India-Mauritius double income tax treaty that would, among other things, permit India to tax a Mauritian resident on capital gains arising from the sale of...more

Potential tax consequences of Brexit from a German perspective

On 23 June, the UK is holding a referendum to decide whether it should leave or remain in the European Union. A vote to leave the EU (the so-called Brexit) would not only have repercussions from a tax perspective for the UK....more

India-Mauritius Tax Treaty Amended

The amendments are a result of long-drawn negotiations between the two countries. India and Mauritius signed a Protocol on May 10 to amend the India-Mauritius double taxation avoidance treaty. The Protocol grants India...more

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more

Weekly Web Wrap-Up

Welcome to Sheppard Mullin’s Weekly Web Wrap-Up, a quick list of the past week’s top news in the social media, gaming, and virtual goods and currencies industries curated by Social Media & Games Team. Here are some of the...more

Treasury Proposes Fundamental New Limitations on Related Party Lending Transactions – With Retroactive Effect!

The U.S. Treasury Department has very recently and unexpectedly released significant guidance that promises, if finalized, to fundamentally limit the circumstances under which related corporations (and, in some cases,...more

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

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