News & Analysis as of September 20, 2024

Income Taxes › Royalties

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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 -

Form SD Deadline Approaching for Resource Extraction Issuers: Reminder and FAQs

Baker Botts L.L.P. on 8/27/2024

As previously discussed in our Client Alert issued on December 18, 2020 (available here), the U.S. Securities and Exchange Commission (the “Commission”) adopted its final rule (the “Final Rule,” available here) requiring...more

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on 1/4/2024

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Activities Contrary to Public Policy – Revoking the Tax Exempt Status of Universities

Rivkin Radler LLP on 11/9/2023

It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more

Establishing A Business Entity In Lithuania (Updated)

International Lawyers Network on 3/10/2023

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

Tax Court in Brief | 3M Company v. Comm’r | Allocation of Income for Subsidiary License or Use of Intellectual Property; Validity...

Freeman Law on 2/14/2023

Summary: In this 346-page opinion (including multiple concurring opinions and dissents) the Tax Court addresses federal income tax issues arising from 3M Company (3M) and its domestic and foreign subsidiaries’ (Subs)...more

U.S. and Mexico | Trademark Royalties and Tax Considerations

Freeman Law on 12/2/2022

Approximately 30% of the global market is related to intellectual property. While intangible goods cannot be touched or seen, they are all too real. For companies around the world, one of the most important intangible assets...more

Weekly IRS Roundup November 21 – November 25, 2022

McDermott Will & Emery on 11/29/2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 21, 2022 – November 25, 2022...more

Top Trends in Digital Assets for 2022

Foley & Lardner LLP on 8/3/2022

It's no secret that cryptocurrency markets and the larger digital assets economy have been roiled by recent instability, resulting in discussions about how regulatory initiatives, rising inflationary pressure, and public...more

Tax Considerations for Transactions of Non-Fungible Tokens

Foley & Lardner LLP on 4/29/2022

Creators, investors, users, and dealers of non-fungible tokens (NFTs) are at the forefront of the intersection of art, music, sports, entertainment, and technology — and they are simultaneously charting a new path when it...more

Federal Income Tax Characterization of Transactions Involving Computer Programs

Freeman Law on 2/18/2022

The sale of a computer program—it seems simple. But, as illustrated by the Treasury Regulations’ computer program characterization rules, the issue of just what a sale of computer program is can become confusing fast....more

German IP Withholding Tax

White & Case LLP on 11/16/2020

On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more

Taxpayers That Paid The Net Investment Income Tax Or The Additional Medicare Tax Should Consider Filing Protective Claims For...

McCarter & English, LLP on 7/13/2020

Individuals, estates, and trusts that paid significant amounts of the 3.8% net investment income tax or the 0.9% additional Medicare tax in 2016 or later years should consider filing protective claims for refund of those...more

Payers and Payees have Obligations to Comply with Backup Withholding

Foodman CPAs & Advisors on 12/20/2019

Backup Withholding requires a payer to “withhold tax” from payments that are not otherwise subject to withholding. A Taxpayer (payee) may be subject to Backup Withholding if it...more

Wisconsin appellate court affirms Microsoft’s sourcing of receipts

Eversheds Sutherland (US) LLP on 11/6/2019

On October 31, 2019, the Wisconsin Court of Appeals rejected the Wisconsin Department of Revenue’s (DOR) position in Wisconsin Department of Revenue v. Microsoft Corporation, Case No. 2018AP2024 that Microsoft should “look...more

French legal and regulatory update - July/August 2019

Hogan Lovells on 9/30/2019

The Paris office of Hogan Lovells is pleased to provide this English language edition of our monthly e - newsletter, which offers a legal and regulatory update covering France and Europe for April 2018. ...more

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on 12/13/2018

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

UK Budget 2018 – Key Tax Measures

Cadwalader, Wickersham & Taft LLP on 11/1/2018

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on 1/3/2018

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

House Passes Tax Bill; Senate Proposal on Track for Vote

Patterson Belknap Webb & Tyler LLP on 12/4/2017

On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced H.R. 1, the “Tax Cuts and Jobs Act” (the “Initial House Bill”). Our previous alert discussed the possible impact of certain provisions...more

2016 Year-End Estate Planning Advisory

Katten Muchin Rosenman LLP on 11/22/2016

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

MoFo New York Tax Insights - Volume 7, Issue 8

Morrison & Foerster LLP on 8/5/2016

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

U.S. Pre-Immigration Tax Planning

Carlton Fields on 1/6/2016

The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

Use of Estonia in U.S. International Tax Planning

Bilzin Sumberg on 8/24/2015

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

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Income Taxes › Royalties

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