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Tax Treaty Corporate Taxes Tax Liability

Cadwalader, Wickersham & Taft LLP

Hargreaves Property: What Does the Latest Decision Mean for UK Withholding Tax?

In many respects, the Upper Tribunal’s decision in Hargreaves Property  will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to...more

Cadwalader, Wickersham & Taft LLP

Pin-pointing Residence

The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

Freeman Law

Reviewing a Foreign Legal Structure

Freeman Law on

Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Freeman Law

Navigating the Branch Profits Tax

Freeman Law on

The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more

Bilzin Sumberg

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

Bilzin Sumberg on

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

Morrison & Foerster LLP

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

Skadden, Arps, Slate, Meagher & Flom LLP

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more

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