Multinationals

News & Analysis as of

The Australian Government increases pressure on multinational tax avoidance: Diverted Profits Tax introduced

INTRODUCTION AND OVERVIEW - The Australian Government released draft legislation on 29 November 2016 to implement a UK-style DPT with effect from 1 July 2017. The DPT targets 'significant global entities' (those...more

Anti-bribery compliance in India: Both sword and shield

In recent years, both the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have stepped up their enforcement of the Foreign Corrupt Practices Act (FCPA), including to address...more

"Double Trouble": The Kenyan Constitution and DTAs

Controversy stalks international corporate taxation. With the integration of national economies and the promotion of Foreign Development Investments (FDIs), international corporations’ presence in multiple jurisdictions with...more

What Trump’s Tax Plan Means For Canada

The election of Donald Trump combined with Republican control of Congress means that U.S. tax reform has suddenly gone from totally impossible to highly likely. The specifics of that reform are not known but the...more

Advance pricing agreements: a new era

There has been a significant amount of negative press recently concerning tax rulings and advance pricing agreements (APAs); negativity that has been fuelled by the European Commission's state aid investigations, Lux leaks...more

Building a global team for cross-border investigations: key points

With many internal investigations today involving multiple markets, it is crucial for companies to build cross-border investigation teams that can efficiently and effectively address a multitude of issues. The ideal...more

IRS and Treasury Issue Final Regulations Under §385 Classifying Interests in a Corporation

On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more

One Step Back, One Step Forward: New Debt-Equity Regulations Narrow Their Focus on Earnings Stripping

Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more

Arguing the business case for respecting human rights

The business case for respecting human rights is becoming increasingly evident. Not only does it fulfill a business’ responsibility to be an ethical actor in society, it is also an integral part of sound risk management, good...more

Impact of New Tax Regulations on Intercompany Debt Obligations

The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more

In the Global Trenches: Making Sense of the Global Economies

On a daily basis, there’s regular media references to trade, global economies, emerging markets, BRICS – and now CIVETS and the Next Eleven. There’s continuous debate whether the category of emerging markets is even valid...more

European Commission publishes an EU corporate tax system

Today the European Commission published three corporate tax directives that potentially will apply in 27 Member States (28 - UK) of the European Union. These corporate tax directives include: the Common Consolidated Tax Base...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Discovery of Nonparty Foreign Affiliates Must Be Tempered by Proportionality

The court’s opinion affirms the principle that relevance, even in the context of a foreign affiliate, must always be tempered by considerations of proportionality, thereby providing defendants an effective argument when...more

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

European Health Care Compliance Challenges (And Solutions)

Life sciences and health care companies (“health care companies”) rightly invest a significant amount of time and money into ensuring compliance with health care regulations in the countries in which they are based, but...more

[Event] "Americas Labor & Employment Law Conference: Managing a workforce across the Americas and beyond" - Dec. 8th-9th, Miami,...

Attorneys from FordHarrison and Ius Laboris, the global Alliance of leading labor and employment law firms, will join in-house counsel to discuss the many challenges faced by multinational companies. The conference is aimed...more

Three Restatements Conclude with SEC Enforcement Action

Following a restatement of its financial statements, many firms are investigated by the SEC and later named in an enforcement action. For Weatherford International PLC, three was the charm – following its third restatement in...more

September 2016 Special Immigration Alert

I. DOS Announces 2018 Diversity Lottery - The U.S. Department of State (“DOS”) just released its instructions for the DV-2018 Diversity Visa (DV-2018) lottery. The registration period begins on Tuesday, October 4,...more

Key Takeaways: Use of Stichtings as an M&A Defence Measure; Contrasting English and Delaware Law

Skadden and Erskine Chambers recently hosted a series of comparative corporate law events in conjunction with the University of Pennsylvania Law School; Queen Mary University of London School of Law; New York University...more

Changes to Dutch dividend withholding tax rules

Today, the Dutch Ministry of Finance announced that it intends to introduce two important changes to the Dutch dividend withholding tax rules...more

Digesting the €13 Billion Apple-EU Tax Ruling

King & Spalding experts assess what international businesses need to be aware of following the EC's ruling on State Aid in the Apple case - Partners in King & Spalding’s tax department have shared their perspectives and...more

10 Steps to Mitigate EU State Aid Exposure on Tax Arrangements

As the European Commission reviews whether tax arrangements conform with State aid rules, companies active in Europe should ensure their fiscal regimes comply with EU law. In recent years, the European Commission (the...more

What The FCC’s Foreign Ownership Move Means To You

In a notice of proposed rule making that impacts existing US radio broadcasters in only a most ancillary way, the FCC is proposing to streamline and make more transparent its review and coordination of foreign ownership...more

Overview of Luxembourg Tax Developments - September 2016 - Issue 01

This report summarizes some of the main Luxembourg tax developments that took place between the end of 2015 and August 2016. The selected developments are mainly relevant to companies and the international tax...more

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