International Tax Issues

News & Analysis as of

Brexit Headline Checklist

This checklist is designed to set out some of the key questions which businesses will need to consider in their initial planning phase as they evaluate their existing structures and operations and the potential impact of...more

Taking a Gap Year: Delayed U.S. CbC Reporting Creates Hassle for U.S. Multinationals

Action 13 of the Organisation for Economic Co-operation and Development’s (OECD) final base erosion and profit-shifting (BEPS) report suggested the adoption of a standardized mechanism for transfer-pricing reporting. Per the...more

“Spider Webs”, “Panama Papers” and IRS

IRS has asked involved U.S. taxpayers to come forward before IRS reads and dissects the “Panama Papers”. IRS will “plan how to use the huge trove of leaked documents to catch criminals — and urged Americans to come clean now...more

Dawn raids: How to prepare for, manage, and mitigate the increasing risk to multinational tech companies

Dawn raids and enforcement actions throughout Europe are becoming more and more prevalent. And increasingly, the targets of these raids are multinational tech companies with foreign headquarters, which through their global...more

Global VAT Guide 2016 - Cross border supplies of intangible services, rights and digital content

Focusing on supplies of intangibles, such as services, intellectual property rights and digital content, we consider this Global VAT Guide to be timely, given that revenue authorities throughout the world are increasingly...more

Global Tax News: India announces fundamental changes to the India-Mauritius double tax treaty

The Government of India announced in a press release dated May 10, 2016 that Mauritius and India have signed a protocol amending the agreement for avoidance of double taxation with Mauritius. The text of the protocol is...more

Four Things You Need to Know About the Mauritius-India Protocol

International investors have frequently used Mauritius holding companies for their Indian investments, seeking to take advantage of the exemption under the India-Mauritius income tax treaty (the “Mauritius Treaty”) from...more

First FATCA Conviction!

On May 9, 2016, the Department of Justice (DOJ) announced its first FATCA conviction. It appears to be the beginning of criminal prosecutions by the DOJ against apparent or alleged violations of FATCA reporting requirements....more

Russian Box Office: Proposal to Tax Hollywood Films

Death and Russian Taxes - The Russian government has found another way to make 2016 “The Year of Cinema.” Rather than increasing direct support for films, Russian legislators may impose a tax on foreign films. The...more

Your daily dose of financial news The Brief – 4.6.16

Talk about a regulation with teeth. Within days of the Treasury Department announcing new rules meant to discourage corporate tax inversion deals, Pfizer and Allergan announced they were scrapping their planned $152 billion...more

Poland: new tax on banks and other financial institutions

Poland’s Banking Tax Act, introducing a tax on banks and insurance companies in Poland, is in force. The Banking Tax Act applies to selected financial institutions - domestic banks, consumer lending institutions and...more

UK Budget 2016 – Key Tax Measures

The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more

International Tax Advisory: America’s Next Tax Model

The Treasury recently released a revised U.S. Model Income Tax Convention (the “2016 Model”), the U.S. starting point for bilateral treaty negotiation, last updated a decade ago. In May 2015, the Treasury circulated several...more

Private Placement Exemption: New UK withholding tax exemption for private placements

The new rules at a glance - Broadly, from 1 January 2016, there will be no UK withholding tax on interest payments on a loan/security which meets all of the requirements below: - not listed on a recognised stock...more

Dutch Presidency releases BEPS Roadmap

Following the release of the anti-tax-avoidance (ATA) package on January 28, 2016 by the European Commission, the Dutch Presidency of the Council of the European Union presented an EU-Base Erosion and Profit Shifting (BEPS)...more

International Tax Advisory: No Love Lost Between Taxpayer Topsnik and the Tax Court

In late January, the Tax Court handed another loss to Gerd Topsnik (Topsnik v. Comm’r, Jan. 20, 2016). Topsnik last encountered the Tax Court in a 2014 case, in which he unsuccessfully argued that “informally” abandoning his...more

Global Tax News - February 2016

The European Commission has released its highly anticipated anti-tax-avoidance package. The package, released January 28, 2016, contains proposed rules and recommendations to avoid aggressive tax planning within the...more

Draft law: Russian VAT on software license transactions and e-commerce services

On 24 December 2015 a draft law was brought before the State Duma introducing important changes to the VAT taxation of software supply transactions and IT services ('Draft Law'). VAT on e-commerce services supplied to...more

Focus on Tax Strategies & Developments - January 2016

Protecting Americans from Tax Hikes Act of 2015—the Year-End Legislation f/k/a Extenders - Just in time for Christmas, Congress passed, with bipartisan support, and the President signed, the “Protecting Americans from...more

Australian GST Reform: Cross-Border Transactions

The Australian Government has announced three GST reform measures impacting cross-border transactions, and most particularly inbound supplies made from outside Australia. If enacted, the reforms will address the...more

Washington Outlook for 2016

Welcome to 2016 and our annual look at what’s in store for the United States Congress in the coming year. Here you will find a preview of the US legislative agenda as well as a look at the Obama Administration’s regulatory...more

International Tax Advisory: New Law Brings Some Welcome FIRPTA Changes

On December 18, President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Despite the new law’s name, a number of its provisions affect foreign investors. The PATH Act introduces several...more

Annulment of the European Commission´s decision regarding the former "Spanish tax lease structure" - EU General Court Decision:...

Background - On December 17, 2015 the EU General Court of Justice (EUGC) pronounced on appeals of joined matters T-515/13 Kingdom of Spain vs Commission and T-719/13 Lico Leasing, S.A., E.F.C. and Pequeños y Medianos...more

A Buyer’s Market for MLPs in 2016

Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the After-Tax Investment Return of Foreign Investors in MLPs - Overview - Master Limited Partnerships are publicly traded partnerships....more

White & Case ECB News – Issue 2, 2015: An update on country rankings – operating employee share plans around the world

Since our last issue in August, we have continued to monitor countries which present significant risk to issuers and administrators when implementing and operating share plans, and highlighted countries which are not...more

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