News & Analysis as of

International Tax Issues

Focus on Tax Strategies & Developments - April 2017

by McDermott Will & Emery on

Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more

QDOT-ting I's and Crossing T's: Estate Tax Planning for Non-United States Citizen Spouses

by Ward and Smith, P.A. on

Individual and corporate citizens from countries around the world have moved to North Carolina and contributed materially to our state's economic, educational, and cultural growth. Foreign direct investment ("FDI") in North...more

SEC Staff Relaxes Limitations under 1940 Act to Permit Certain Global “Master-Feeder” Arrangements, Although Obstacles Remain

by Dechert LLP on

The Staff of the U.S. Securities and Exchange Commission (SEC) on March 8, 2017 issued a no-action letter (Staff Letter) in response to a request from Dechert LLP for assurance under Section 12(d)(1) of the Investment Company...more

Two Important New International Tax Filings

by Charles (Chuck) Rubin on

While not the only international reporting changes that are occurring, there are two significant ones that apply for the current filing season for 2016 returns. First is the FBAR, which reports interests in foreign...more

Choose Opt Out Option Wisely in Offshore Voluntary Disclosure Program

Since 2009, the Internal Revenue Service has offered a variety of offshore voluntary disclosure programs (collectively, OVDP) under which a U.S. taxpayer can disclose previously undisclosed offshore activities. However, these...more

Law à la Mode: The future of retail; Green fashion; E-commerce in China; Brexit update: trademarks and design; and more (UK) Issue...

by DLA Piper on

Management, a Belgian national and expert on retail management and customer experience for fashion, department stores and home improvement retailing. He tells us about the changes he has seen in the retail sector over the...more

IRS Agent Discusses the Look-Back Period for Filing Delinquent International Information Returns

We represent a client who may need to file delinquent international information returns under the IRS Delinquent International Information Return Submission Procedures. These procedures invite taxpayers who meet the...more

Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again

by Jones Day on

On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary... ...more

"Key Takeaways: Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions"

On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

by Foodman CPAs & Advisors on

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

Key Takeaways: Prospects for US Business Tax Reform — What You Need to Know

On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more

IRS Criminal Investigation Unit (IRS-CI) will find you!

by Foodman CPAs & Advisors on

Due to the Foreign Account Tax Compliance Act (FATCA) and the work of IRS special agents, international tax transparency is here. There is virtually nowhere to hide. On 1/18/17, the Department of Justice (DOJ) reported that...more

Upheaval in the German Restructuring Market – Need-to-know Facts and Alternative Tools

by Latham & Watkins LLP on

To date, a debt waiver has been frequently used as a tool to successfully restructure German based companies in financial difficulties. A decision of the German Federal Fiscal Court (Bundesfinanzhof) published on...more

ATO Taxpayer Alert: Concerns about Certain Stapled Groups

by K&L Gates LLP on

In Taxpayer Alert TA 2017/1, the Australian Tax Office (ATO) has announced that it will be targeting arrangements which fragment integrated trading businesses, with particular emphasis on the inappropriate use of stapled...more

ATED Returns Are Due in April

by McGuireWoods LLP on

It is that time of year again when we like to draw your attention to the need to prepare and submit your Annual Tax on Enveloped Dwellings (ATED) Returns. By 30 April 2017, you must have completed your ATED Return and...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

Registration with the RF tax authorities aimed at payment of VAT by foreign e services providers

by Dentons on

Dentons’ Russia Tax practice would like to remind readers that, starting 1 January 2017, foreign companies providing e-services are required to undergo special tax registration according to the procedure of Clause 4.6 of...more

Some Tax Law Changes That Take Effect in 2017

by Charles (Chuck) Rubin on

No new tax legislation has come forth yet, but per tax laws passed in prior years, some changes in the law will occur in 2017. Chief among them...more

Real Estate Advisory: Canada Revenue Agency Announces Changes to Treatment of U.S. LLLPs and LLPs

by Sherman & Howard L.L.C. on

The Canada Revenue Agency (CRA) recently announced a change in the treatment of U.S. limited liability limited partnerships and U.S. limited liability partnerships (the “Entity Types”) for Canadian tax purposes. For Canadian...more

2016 Year-End Tax Update: Okay, Now What?

by Cozen O'Connor on

In last year’s materials, loosely styled “Make America Great Again!,” we ruminated upon (and also thought about) what role, if any, federal income taxes might play in helping to make America great again, once the interminable...more

New Tax Information Exchange Agreement Between the United States and Argentina

The governments of Argentina and the United States signed on December 23rd, 2016, a new tax information exchange agreement (“TIEA”). Jack Lew, U.S. Treasury Secretary, stated that the TIEA will allow for important...more

World Bank publishes Transfer Pricing Handbook for developing countries

by DLA Piper on

On 23 December 2016, the World Bank Group published a transfer pricing handbook "Transfer Pricing and Developing Economies: A Handbook for Policy Makers and Practitioners". The Handbook, which comprises eight chapters...more

Focus on Tax Strategies & Developments - December 2016

by McDermott Will & Emery on

Significant Changes in US Tax System Likely - In the short time since the surprising election of Donald J. Trump as the 45th president of the United States, much already has been written about the likelihood and likely...more

Trump’s Promised First 100 Days: What Asian Businesses Need to Know

by Morgan Lewis on

Companies operating in Asia should take heed of five areas the US president-elect has said he will act on in his first 100 days, which could provide potential opportunities and challenges for Asian businesses—including the...more

Tax Truths: Volume 1, No. 2 – December 2016

by Ballard Spahr LLP on

AN ANALYSIS OF TAX LAW PROPOSALS OF THE PRESIDENT-ELECT AND THE HOUSE - President-elect Trump made tax reform a highlight of his campaign, calling for fewer tax brackets, lower individual rates, and reduced corporate tax...more

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