News & Analysis as of September 22, 2024

Income Taxes › BEPS

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Tax Base Erosion: Canada Responds with Draft EIFEL Rules Legislation

Stikeman Elliott LLP on 10/31/2023

On August 4, 2023, the Department of Finance released an updated version of the draft legislation that will incorporate the excessive interest and financing expense limitation rules (“EIFEL Rules”) into the Income Tax...more

Luxembourg Draft Budget Law 2023: The Most Awaited Reverse Hybrid Clarification

Goodwin on 10/26/2022

On 12 October 2022, the finance minister presented the Luxembourg budget bill for fiscal year 2023. For corporate tax payers, and particularly for funds, there is a most welcomed clarification on the scope of the...more

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on 9/29/2022

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Country-by-Country Reporting

Freeman Law on 9/27/2022

In recent years, tax authorities across the globe have adopted a number of OECD-led initiatives aimed at curbing the ability of multinational enterprises to engage in so-called Base Erosion and Profit Shifting (BEPS) (i.e.,...more

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on 9/7/2021

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

International Tax Treaty: Australia

Freeman Law on 12/8/2020

Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

International Tax Treaty: Mexico

Freeman Law on 11/12/2020

The world’s most populous Spanish-speaking nation. Mexico is a Federation comprised of 32 states, being Mexico City the capital of the country. The government of Mexico is divided in three branches: the Legislative Branch in...more

UK Tax Round Up - October 2020

Proskauer Rose LLP on 11/9/2020

UK COVID-19 Developments - UK Prime Minister’s statement on COVID-19 - On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more

International Tax Treaty: Canada

Freeman Law on 11/6/2020

Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

Three Years, Two Pillars and One New Headache for Investment Funds

Skadden, Arps, Slate, Meagher & Flom LLP on 11/5/2020

Fund sponsors, investment advisors and other financial market participants would be forgiven for not concerning themselves with tax initiatives originally targeted at the digital economy. However, with the latest technical...more

BEPS 2.0 - International Tax Reform Primer for SALT Experts

BakerHostetler on 9/17/2020

It can be a little intimidating for a state tax expert to stand around the water cooler with international tax experts that casually throw around terms like BEPS, Pillar 1, Pillar 2, Digital Services Taxes, OECD, GloBE, etc....more

Taxation & Representation - February 2020

Brownstein Hyatt Farber Schreck on 3/5/2020

TAX TIDBIT - New National Taxpayer Advocate. The Internal Revenue Service (IRS) announced that a new National Taxpayer Advocate will likely be in place by April. According to an internal memo sent by IRS Commissioner...more

Mexico 2020 Tax Reforms

White & Case LLP on 11/8/2019

The Mexican Congress approved with some adjustments the Tax Bill presented by the President on September 8, 2019, that included a proposal of Decree through which various provisions of the Income Tax Law, the Value Added Tax...more

Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)

Proskauer - Tax Talks on 1/28/2019

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more

UK Tax Round Up - September 2018

Proskauer Rose LLP on 10/8/2018

UK Case Law Developments - Entrepreneurs' relief – voting rights not imputed for equitable reasons - In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more

Business Tax Reform – Key Provisions

Orrick, Herrington & Sutcliffe LLP on 12/20/2017

Congress is set to vote on the tax reform bill, entitled the "Tax Cuts and Jobs Act," after resolution in conference committee of the differences between the House and Senate versions of the bill. Here is a quick look at the...more

Seventeen Provisions to Watch in the Senate Tax Reform Bill

Cadwalader, Wickersham & Taft LLP on 12/13/2017

On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more

Google Ireland Limited does not have permanent establishment in France

Orrick, Herrington & Sutcliffe LLP on 9/12/2017

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

BEPS: OECD Releases Multilateral Tax Treaty Convention

Proskauer - Tax Talks on 12/6/2016

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more

Tax Announcements in the UK’s Budget 2016

Proskauer - Tax Talks on 3/17/2016

The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our...more

The Global Crackdown on Profit Shifting

Troutman Pepper on 8/27/2014

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your...more

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Income Taxes › BEPS

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