Income Taxes, Double Taxation

GE Financial Investments: What Determines Residency?

Cadwalader, Wickersham & Taft LLP on 8/29/2024

Background - In GE Financial Investments Limited the Court of Appeal (“CoA”) overturned the Upper Tribunal’s (“UT”) decision and held that double taxation relief was not available under the UK-US double tax treaty (the...more

Avoiding Double Taxation: The UAE's Legal Framework for Mitigating International Tax Liabilities

Awatif Mohammad Shoqi Advocates & Legal... on 8/5/2024

Double taxation arises when the same income is taxed in two different jurisdictions, potentially leading to excessive tax burdens for individuals and businesses. The UAE has developed a comprehensive legal framework to...more

Burlington: Good News for the Secondary Debt Market

Cadwalader, Wickersham & Taft LLP on 7/29/2024

In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

Holland & Knight LLP on 7/8/2024

The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Establishing a Business Entity in Singapore (Updated)

International Lawyers Network on 2/29/2024

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

[Webinar] Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Income and Expenses, FTCs - March...

Strafford on 2/22/2024

This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more

Buying and Selling Real Estate in Michigan (Updated)

International Lawyers Network on 1/31/2024

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER MICHIGAN LAW - I. STANDARD FORMS OF AGREEMENTS - A. Offers to Purchase that are accepted by sellers are the typical form of purchase contract for residential properties....more

Establishing a Business Entity in Denmark (Updated)

International Lawyers Network on 1/4/2024

1 TYPES OF BUSINESS ENTITIES - There are several forms of business entities in Denmark and there are a wide range of possibilities for establishing a business entity in Denmark. The most suitable entity depends on a...more

U.S.-Chile Income Tax Treaty Enters Into Force

A&O Shearman on 12/28/2023

On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more

Chilean tax treaty enters into force

Eversheds Sutherland (US) LLP on 12/22/2023

On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more

US-Chile Income Tax Treaty Approval Process Continues

Kramer Levin Naftalis & Frankel LLP on 11/9/2023

On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty) to the Chilean Congress for approval. Chilean tax practitioners...more

Pin-pointing Residence

Cadwalader, Wickersham & Taft LLP on 8/24/2023

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

Buehler Doesn’t Get a Day Off from Double Taxation

McDermott Will & Emery on 5/12/2023

The California Office of Tax Appeals (OTA) recently held that a California resident’s income tax paid to Massachusetts from the sale of his membership interest in a limited liability company (LLC) doing business in...more

UK Tax Round Up - March 2023 - 2

Proskauer Rose LLP on 3/29/2023

Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

Establishing A Business Entity In Singapore (Updated)

International Lawyers Network on 3/23/2023

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

New York’s Convenience of the Employer Rule – New Jersey and Connecticut Respond

Rivkin Radler LLP on 3/1/2023

History is replete with examples of leaders who chose to battle, or who were forced into defending against, enemies on two fronts. Rarely did it end well for the combatant that occupied the middle ground. In a sense, New...more

Buying and Selling Real Estate in Michigan (Updated)

International Lawyers Network on 2/28/2023

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER MICHIGAN LAW - I. STANDARD FORMS OF AGREEMENTS - A. Offers to Purchase that are accepted by sellers are the typical form of purchase contract for residential properties. The...more

Establishing A Business Entity In Denmark (Updated)

International Lawyers Network on 2/2/2023

1 TYPES OF BUSINESS ENTITIES - There are several forms of business entities in Denmark and there are a wide range of possibilities for establishing a business entity in Denmark. The most suitable entity depends on a...more

Spain releases its long awaited draft list of non-cooperative jurisdictions

Hogan Lovells on 1/19/2023

On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more

Tax Court in Brief | Smith v. Comm’r | Closing Agreement and Malfeasance of Fact

Freeman Law on 1/3/2023

Short Summary: The case discusses the validity of a closing agreement and if a taxpayer can set aside such agreement under malfeasance or misrepresentation of fact....more

Don’t Double Tax Your Business: How The PTE Tax Can Impact the Valuation of Pass-Through Entities

J.S. Held on 11/2/2022

Taxes can have a significant impact on the value of a business. Pass-through entities such as S-Corporations and partnerships generally do not pay any taxes since the income is passed through to the individual shareholder or...more

UK Tax Round Up - October 2022

Proskauer Rose LLP on 11/1/2022

Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more

UK Tax Round Up - September 2022

Proskauer Rose LLP on 9/30/2022

Welcome to September’s edition of the UK Tax Round Up. In addition to the headline-grabbing 2022 Growth Plan announced by the UK Chancellor, there have been a number of interesting cases this month including the First-tier...more

Today in Tax: U.S. Tax Treaty Updates—Chile, Croatia, and Hungary

Miller Nash LLP on 8/5/2022

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD)...more

Establishing A Business Entity In Singapore (Updated)

International Lawyers Network on 3/16/2022

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

Income Taxes › Double Taxation

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