Foreign Tax

News & Analysis as of

Tax Planning for the Privatization of the Space Industry

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

The Shadow Transfer Pricing Rules: Crediting Foreign Taxes

At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more

Credit for Foreign Taxes Paid Not Available Against New 3.8% Net Investment Income Tax

Previously, many U.S. citizens living abroad eliminated their U.S. income tax liabilities with a credit for foreign taxes paid; however, individuals who are subject to the new 3.8 percent net investment income tax (NIIT) may...more

CFPB updates remittance rule small business guide and makes “clarificatory” amendment and technical correction to rule

The CFPB has updated its small business guide on the remittance transfer rule to reflect the changes to the rule that were made this past May dealing with the scope of the error resolution procedures, disclosure of recipient...more

OECD releases “BEPS” Action Plan – a sweeping international tax effort to combat base erosion and profit shifting

The OECD’s Committee on Fiscal Affairs (CFA) has published its Action Plan to address Base Erosion and Profit Shifting (BEPS). This sweeping international effort aims to combat a comprehensive range of international tax...more

Native Title Taxation Measures Pass In Final Sitting Week (Australia)

SUMMARY - In its final sitting week, the Commonwealth Parliament passed three pieces of legislation which include important measures aimed at clarifying the taxation treatment of payments and benefits provided under...more

"Star Wars" – How to Win the Tax Battle When Your Talent Clients Work Abroad

In this article: - Income Tax - Other Foreign Taxes -- Vat And Social Security Taxes - Foreign Tax Credit Planning - U.S. Withholding Obligations - Use Of Loan Out Company -...more

As Nonprofits Expand Their Global Reach, a Special Focus on Tax, Trademarks and the Foreign Corrupt Practices Act

In this presentation: - Introduction - Trademark/Brand Strategy and Protection - U.S. Foreign Corrupt Practices Act and Anti-Corruption - Cross-Border Tax Planning and Compliance Please see...more

German Federal Tax Court: Distributions from U.S. Trusts Are Subject to German Gift Tax

The German Federal Tax Court clarified that distributions from foreign trusts to beneficiaries resident in Germany are subject to German gift taxation, but did not address the possible imposition of both gift and income tax...more

CFPB Proposes Revisions to Rules on International Money Transfers by Consumers

The Consumer Financial Protection Bureau (CFPB) recently issued proposed changes to the rule it originally proposed on January 20, 2011, governing certain electronic money transfers by consumers that was required by the...more

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

PPL Corp. v. Commissioner of Internal Revenue

Brief For Southeastern Legal Foundation, Chamber of Commerce of the United States of America, CATO Institute, et al, As Amici...

PPL, an American energy company, bought one of many state-owned British utilities privatized in the 1980s. In 1997, PPL became subject to the U.K.’s new “windfall tax,” which was based in part on “profit-making value”— the...more

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