International Tax Issues

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International Tax News - July 2014

BITCOIN FORGES AHEAD: 3 QUICK LOOKS - Bitcoin is a decentralized peer-to-peer payment system that exists virtually and is unlimited by the constraints of countries, government or time. In an age when business leaps...more

The U.S. Tax Code: Love It, Leave It, Or Reform It!

On July 22, 2014, the Senate Finance Committee held a hearing titled, “The U.S. Tax Code: Love It, Leave It, or Reform It!” The general topic of the hearing was international taxation, with a sharp focus on recent and...more

Puerto Rico: A Haven for Manufacturers?

Perhaps not surprisingly to those familiar with the tropical island, manufacturing remains a key driver of economic activity in Puerto Rico. Indeed, manufacturing accounts for 45% of Puerto Rico’s GDP (compared to 11% in the...more

New Spanish Tax Regime for Qualifying Bond Offerings May Boost High-Yield Bond Markets

New rules will facilitate privately held companies’ access to bond financing and reassure Spanish investors. On June 28, 2014, Law 10/2014, on the organization, supervision and solvency of credit institutions (Law...more

Creating and Registering Security Interests Over Assets of a BVI Business Company

Entering into security financing transactions with BVI Business Companies (BCs) is a familiar part of the global financial services landscape given the use and presences of BCs. The ease of use of BCs in these types of...more

Focus on Private Equity - July 2014

In This Issue: - Latin American Private Equity on the Rise - Tax Considerations When Acquiring Non-U.S. Portfolio Companies—Mitigating Subpart F Inclusions - Private Equity Funds at Higher Risk of...more

Time For a New Home?

The high number of companies, mostly U.S., eyeing acquisitions or ventures that will allow them to redomicile their business in the UK and Ireland is a major theme of this report. Mostly, it is about tax. But there is quite a...more

The Many Benefits of British Virgin Islands Investment Funds

One of the main reasons the British Virgin Islands (BVI) is often chosen as a jurisdiction for investment managers to set up their fund vehicles is the flexibility the legislative regime provides for structuring these funds....more

False Foreign Gift Claims and Wire Fraud

A scheme that some dual national taxpayers have used involves claiming exemption from foreign jurisdiction taxation because they are U.S. taxpayers and then not reporting the offshore account or its income as required by U.S....more

M&A Update | Inversions: The View from Ireland

On June 25, 2014, Ireland’s Taoiseach (Prime Minister) Enda Kenny and Minister for Finance Michael Noonan, among others, met with Cadwalader Chairman-elect and Corporate Group Co-Chair James C. Woolery in Dublin regarding...more

Tax authorities updated their interpretation of certain transfer pricing issues

On 1 July 2014, the Ministry of Revenues and Levies of Ukraine has issued Order #368 "On amendment of Generalized tax consultation on transfer pricing related issues, adopted by the order #699" (hereinafter - the Order) which...more

European Commission Uses EU State Aid Rules Against Aggressive Tax Planning by Multinational Companies

EU Member States are prohibited from granting to companies selective advantages that qualify as State aid within the meaning of Article 107(1) of the Treaty on the Functioning of the European Union (TFEU) without the prior...more

VAT recovery and pension schemes: Where are we now?

HMRC’s policy on reclaiming VAT on investment management and other costs remains under review in the light of two recent decisions from the Court of Justice of the European Union. The first of these cases, PPG...more

Is Your Company Prepared For The Potential Impacts Of The Stop Corporate Inversions Act of 2014

As Congress Seeks Additional Funding, Inversion Proposal Emerges - Throughout the past several weeks, Pfizer’s attempt to acquire AstraZeneca has garnered significant congressional and media attention. Pfizer, a U.S....more

Tax Effective Use by Canadian Online Retailers of Bermuda Operations for International Expansion - 2011 Canada-Bermuda Tax...

E-tail Foreign Market Opportunity - The growth of online retail sales has globally outstripped the growth of all other retail channels, including during the last recession. For example, in England during 2012, it has...more

Tax Evasion Gets Harder as FATCA Goes into Effect July 1

The Internal Revenue Service (IRS) will have more leverage over those seeking to minimize their tax bills by moving assets outside the U.S. when the Foreign Account Tax Compliance Act (FATCA) takes effect on July 1, 2014....more

IRS Commissioner Hints That OVDP Modifications Are in the Works

Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more

IRS Unveils New Compliance Program

According to the Miriam Webster dictionary, credibility is defined as "the quality or power of inspiring belief." When IRS Commissioner John Koskinen took office, one of his many roles involved trying to restore the integrity...more

2013 Foreign Financial Account Reporting Requirements

U.S. citizens or residents who owned, directly or indirectly through an entity, beneficially, or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding...more

Recent Change In Consumption Tax In Japan

The OECD Global Forum on VAT held meetings in Tokyo on 17–18 April 2014. These meetings follow the Global Forum’s first meeting in Paris in November 2012. The meetings in Tokyo were part of a series of events commemorating...more

Colombia Seeks Foreign Investment to Expand Timberland Plantations

Colombia plans to double its cultivated acreage from one million to two million hectares by 2020, according to Rubén Darío Lizarralde, the country’s Minister of Agriculture and Rural Development. Lizarralde announced the...more

FATCA: Implications for Non-US Funds

A general guide in determining the application of FATCA to non-US funds. I. What Is FATCA? FATCA refers to the US Foreign Account Tax Compliance Act (contained in Sections 1471 through 1474 of the US Internal Revenue...more

FATCA and the Cyprus – US Connection

THE US DEPARTMENT OF TREASURY HAS ANNOUNCED that Cyprus and the US have reached agreement in substance as regards the Inter-Governmental Agreement for FATCA and Cyprus has consented to being included ...more

Defying the odds: the rise of European private equity - The recovery and future prospects of the private equity market in Europe

In This Issue: - Back on its feet: the European private equity picture - An uneven recovery: country and sector focus - Infographic: the European private equity picture - The road to recovery: the...more

China Update

In This Issue: - Quote of the Week - U.S.-China Relations - China News - Energy & Environment and Trade - Excerpt from U.S.-China Relations: China to Participate in RIMPAC for First Time - On...more

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