On November 29, 2013, the Cayman Islands and the U.S. Signed a FATCA IGA. The Cayman Islands IGA is a Model 1B agreement, meaning that FFIs in the Cayman Islands will be required to report tax information about U.S. account...more
On November 19, 2013, Sen. Max Baucus (D-Mont.), Chairman of the Senate Finance Committee, released a Staff Discussion Draft on International Business Tax Reform. The changes proposed in the discussion draft are far-reaching...more
Over the past 12 years, 96 tax related measures have been announced by former governments which have not been legislated. These outstanding tax measures have created uncertainty for taxpayers, of varying degrees. Where a tax...more
The United Kingdom (U.K.) has published an agreed intergovernmental agreement (IGA) with the Cayman Islands. The IGA was signed on 5th November and is intended to improve international tax compliance by providing for domestic...more
I am pleased to present to you DLA Piper’s “Doing Business in Japan” Guide.
Japan is the world’s third largest economy and remains cutting-edge in business. In 2012, 68 Global 500 Companies were headquartered in...more
COLOMBIA ISSUES TAX HAVENS LIST: 4 THINGS TO NOTE FOR THOSE DOING BUSINESS IN COLOMBIA -
Colombia has issued its list of tax havens – an act that will negatively impact the tax effects of doing business in Colombia...more
The U.S. Treasury Department has delayed implementation of FATCA once again. However, this delay may be the last, and a phased implementation of FATCA is scheduled to begin on July 1, 2014. FATCA introduces the potential for...more
Synopsis: Historically, to complete a foreign exchange payment at a Chinese bank as part of a technology or intellectual property agreement, various registrations (with local Ministry of Commerce (“MOFCOM”), the Patent Office...more
On October 15, 2013 the Swiss signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.
As provided in the press reports....more
This newsletter's fifth edition covers key tax matters and developments in Australia, China, Hong Kong, Indonesia, Malaysia, Singapore, Thailand and Vietnam.
Special Webinar Feature
Amid the intense dispute over federal spending and debt, the chairmen of the tax writing committees in the US Senate and the House of Representatives continue their efforts to build a consensus among their members for tax...more
Ukraine’s major transfer pricing reforms took effect on September 1 2013. Generally, the new rules are OECD-based, though some exceptions exist.
While these new and technically complicated rules represent untested...more
FRANCE ANNOUNCES DRAFT 2014 BUDGET – LIGHTER TAX BURDEN FOR BUSINESSES -
France’s draft budget law for 2014 was presented to Parliament on September 25 and is now under discussion in the National Assembly and...more
The IRS recently announced that private practitioner Diana Wollman will begin work as “Director, International Strategy” on September 16, 2013....more
OECD RELEASES “BEPS” ACTION PLAN – A SWEEPING INTERNATIONAL TAX EFFORT TO COMBAT BASE EROSION AND PROFIT SHIFTING -
The OECD’s Committee on Fiscal Affairs has published its Action Plan to address Base Erosion and...more
The OECD’s Committee on Fiscal Affairs (CFA) has published its Action Plan to address Base Erosion and Profit Shifting (BEPS). This sweeping international effort aims to combat a comprehensive range of international tax...more
The Organization for Economic Co-operation and Development has released its ambitious action plan to address base-erosion and profit-shifting. If the political will exists to enact the changes envisaged by the action plan,...more
DLA Piper’s Financial Services International Regulatory team welcomes you to the nineteenth edition of ‘Exchange – International’, an international newsletter designed to keep you informed of regulatory developments in the...more
A. Foreign Persons -
Doing Business or Investing in the U.S.. Foreign persons who plan to do business in the United States or invest in a new or existing U.S. business entity are faced with a...more
The recent Congressional hearings on taxation of multinational corporations drew a lot of focus on the low tax rates and low taxes paid (relative to revenue). Congress expressed outrage that the largest companies in the world...more
In line with our recent coverage of the Internal Revenue Service’s initiatives to pursue illegal offshore tax havens, on May 16, 2013 a Florida couple – Drs. David Leon Fredrick and Patricia Lynn Hough – was indicted by a...more
On April 10, 2013, the White House released its proposed budget for fiscal year 2014. The budget contains significant tax proposals related to renewable energy, research and job creation, as well as numerous changes affecting...more
The Stop Tax Haven Abuse Act and the International Tax Competitiveness Act of 2013 are two parts of a package of three bills introduced in the U.S. House of Representatives on April 15 by Rep. Lloyd Doggett. A significant...more
With a continuation of the general downturn in Government finances across much of Europe, greater efforts are being made to open up the tax base, to clamp down on evasion and reassess the most aggressive avoidance schemes....more
Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more