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Foreign Corporations Holding Companies

Orrick, Herrington & Sutcliffe LLP

The UK Qualifying Asset Holding Company Regime - Highlights

The United Kingdom ("UK") Qualifying Asset Holding Company ("QAHC") regime (at Schedule 2 to Finance Act 2022) comes into force on 1 April 2022. The HM Revenue & Customs ("HMRC") policy paper dated 27 October 2021 states:...more

Miller Canfield

SEC Approves PCAOB Rule Governing Determinations Under the Holding Foreign Companies Accountable Act

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On November 4, 2021, the U.S. Securities and Exchange Commission (SEC) approved the Public Company Accounting Oversight Board's (PCAOB) Rule 6100, Board Determinations Under the Holding Foreign Companies Accountable Act (Rule...more

WilmerHale

SEC Finalizes Rules Implementing Requirements under the HFCAA

WilmerHale on

Yesterday, the SEC adopted amendments to finalize rules implementing the submission and disclosure requirements in the Holding Foreign Companies Accountable Act (HFCAA). These amendments finalize the interim final rules...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

A&O Shearman

Briefing Note on UAE Economic Substance Regulations

A&O Shearman on

Cabinet resolution number 31 of 2019 concerning economic substance requirements was recently published on the Ministry of Finance website. The issuance of this resolution requires companies operating a ‘relevant activity’ in...more

Proskauer Rose LLP

UK Tax Round Up - August 2018

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VAT treatment of supplies of non-employed temps clarified - A recent Court of Appeal case – Adecco v HMRC – clarifies a longstanding question over seemingly contradictory case law on the VAT treatment of employment agency...more

McDermott Will & Emery

Texas Supreme Court Weighs In on Tied House

Late last month, the Texas Supreme Court issued a ruling in Cadena Comercial USA Corp. d/b/a OXXO v. Texas Alcoholic Beverage Commission, finding in favor of the Texas Alcoholic Beverage Commission (TABC) and weighing in for...more

Proskauer Rose LLP

Tax Round Up - April 2017

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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

Patterson Belknap Webb & Tyler LLP

Entering the U.S. Without Entering Its Tax System: Holding Company Structures for U.S. Operations

Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits...more

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