International Tax Issues

News & Analysis as of

Global Tax News - March 2015

Australia's Investment Management Regime reforms 30 MAR 2015 - Australia’s Investment Management Regime (IMR) reforms, initially proposed by the Australian Financial Centre Forum in the Johnson Report in 2009 and the...more

Luxleaks - Challenging the challenges to tax rulings in the EU

The European Commission's recent state aid crusade against so-called sweet deals in the form of tax rulings may have unwelcome consequences never contemplated by the Commission....more

Cayman Portal registration deadline extended

An update was released recently by the Cayman Islands Department of International Tax Cooperation in relation to the status of the Cayman Automated Exchange of Information Portal (Portal) and the requirement for Cayman...more

Real Estate Gazette - Issue 19 (Global)

In This Issue: - INTERNATIONAL: Key Issues For Real Estate In The Implementation Of The AIFMD Across Europe - ASIA: Understanding Four Key Changes To The Hong Kong REIT Code -...more

Overview of the Taxation of Foreign Currency

In this Newsletter: - Determination of the Functional Currency and Definition of a “QBU” - Section 988 — Non Functional Currency Transactions - Section 986 — Translation Rules for Earnings and Profits and...more

India Shows a Way

Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a...more

Global Tax News - January 2015

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

Hybrid Mismatches – UK Proposals for Implementing the BEPS Recommendations

The United Kingdom made its first substantive commitment arising out of the base erosion and profit shifting (BEPS) initiative on 3 December 2014, with the release of a consultation paper on implementing the agreed G20-...more

Happy Holidays – There is a Budget Deal, Now Look Out

The just passed budget deal known as Consolidated and Further Continuing Appropriations Act, 2015 contains a reduction in funding for the IRS. The Bill provides a reduction in total IRS funding of $346 million less than last...more

The use of offshore SPVs in Shariah compliant transactions post-FATCA

In recent years and in the wake of the global financial crisis, international financial centers (IFCs) such as the British Virgin Islands (BVI) and the Cayman Islands (Cayman) have faced unprecedented political and regulatory...more

Minerals Matter - Autumn 2014

Welcome to the latest edition of Minerals Matters. Whilst the economic picture has certainly improved over the last six months, there have been a number of stops and starts along the way. Data suggests further...more

OECD Countries Agree To Share Tax Information

On October 29, representatives from 51 countries, having met at the Global Forum on Transparency and Exchange of Information for Tax Purposes, agreed to address tax havens in exchange for transparency in tax information....more

Orwell’s 1984 30 Year Later

Welcome to 1984 30 years later! One of the most famous quotes from George Orwell’s 1984 is “Big Brother is Watching You.”. This quote is more true now than at any time in past. At the just concluded Global Forum on Tax...more

Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders  [Video]

Nov. 3, 2014 -- Allen Appel, Professor at New York Law School and Director of the International Tax Program, talks with Lee Pacchia about corporate inversions....more

Land and Buildings Transaction Tax: Residential and non-residential property

The Land and Buildings Transaction Tax ("LBTT") will replace Stamp Duty Land Tax ("SDLT") in Scotland on 1 April 2015. LBTT is being introduced under the Land and Buildings Transaction (Scotland) Act 2013 ("the 2013 Act"),...more

China’s State Administration of Taxation actively advances the Base Erosion and Profit Shifting 2014 Deliverables

In September 2014, China’s State Administration of Taxation (SAT) released a Chinese translation of the full text of the G20/OECD Base Erosion and Profit Shifting (BEPS) 2014 Deliverables. This was followed in October 2014...more

Guide To Doing Business in New Zealand: Taxation

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

Death of the “Double Irish Dutch Sandwich”? Not so Fast.

On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning...more

Luxembourg draft budget for 2015 submitted to Parliament

On 15 October 2014, the Luxembourg Minister of Finance submitted the draft budget for 2015 (the Budget Bill) to the Parliament. The Budget Bill does not overhaul the Luxembourg corporate tax environment, however, it proposes...more

Guide To Doing Business in New Zealand: Regulation of Foreign Investment

REGULATION OF FOREIGN INVESTMENT - One of the first matters a foreign company or investor must consider when planning to invest in New Zealand is the impact of New Zealand’s foreign investment policy....more

B.C. Supreme Court Rescinds Land Transfers

In Re 0741508 BC Ltd and 0768723 BC Ltd (2014 BCSC 1791), the British Columbia Supreme Court (“BCSC”) considered whether rescission should be granted in respect of two real estate transactions in which the applicant...more

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part 3 - Inbound Investment Real...

As an undergraduate at West Point, I was a Spanish and Portuguese major. My Brazilian “thing” had already started a decade earlier as a ten year old growing up in the Panama Canal Zone seeing Pele play for his Brazilian team...more

United States and Brazil Sign FATCA Intergovernmental Agreement

The United States and Brazil have signed a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”). The Brazilian IGA is intended to simplify FATCA information...more

Scotland Votes No - What does a “No” vote mean for businesses from a tax perspective?

Scotland has voted against independence. However, it is clear that changes will be made to grant further taxation powers to Scotland. So, despite the "No" vote, major changes are still on the horizon which could impact...more

Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

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