Multinationals

News & Analysis as of

Base erosion and profit shifting - new regulations

International tax issues have never been more prevalent than in today's integrated economic environment and international markets. As the world becomes increasingly globalised and cross-border activities become the norm, the...more

The International Foreign Bribery Taskforce and the rise of international cooperation among anti-corruption authorities

Recent events have called attention to the increasingly global nature of anti-corruption investigations and the rise in international cooperation among anti-corruption authorities. One such event involves the activities of...more

Webinar: Secondment - Sending Staff to Europe

Imagine your company has obtained a major contract to provide services globally, in particular in France, Germany, Italy and the UK. Although you may have offices in these countries, you need to temporarily second...more

International Trade Litigation and the New Trump Administration: Your Top Ten Questions Answered

Globalization and the need to efficiently deploy corporate resources have led many multinational companies to establish global supply networks. Although these efforts often lead to the efficient deployment of capital,...more

SEC: Firm’s IC Failure Equals Liability For Subsequent Acquirer

The books, records and internal control provisions are an integral part of the FCPA. The Commission’s most recent action involving those provisions, however, centers on a claimed internal control failure by a firm when...more

Global investigations – the outlook for 2017

With the arrival of 2017, the pace of cross-border investigations is expected to continue, if not increase.  For multinational companies, the regulatory and enforcement landscape remains one which merits attention, both for...more

Lessons Emerging from Pinnacle Hip Bellwether Trials

In a staggering verdict, a Texas jury recently awarded over $1 billion against Johnson & Johnson (“J&J”) and its subsidiary DePuy Orthopaedics Inc. (“DePuy”) (collectively referred to as “Defendants”) to six California...more

Tax reform: Are you ready for the storm?

You may want to think of tax reform as a pending storm. First, it is sorely needed; it has been a long time since we had the last real one. Second, even though we see storm clouds gathering, we are not exactly sure when it...more

So You’re Going Global! Five Employment Basics for U.S. Companies Expanding Overseas

Your company is doing well in the United States, and you are looking to expand internationally. That can be a very exciting time! But besides the practical logistics (e.g., Do I need to set up a subsidiary to hire someone...more

German tax law changes and their impact on multinationals

On 2 December 2016, the Act for the implementation of the amendments of the EU Administrative Cooperation Directive and of further measures to counter base erosion and profit shifting - having been approved by the Lower House...more

U.S. Antiboycott Compliance: New Federal List Published

Companies doing business in the Middle East take note: The Treasury Department recently published its quarterly list of countries that currently require participation or cooperation with an international boycott, such as the...more

Country by Country: Luxembourg introduces law on country-by-country reporting

On the 13th of December, the Luxembourg parliament voted in favour of a law on country-by-country reporting (CbCR). The conditions for a Luxembourg tax resident company to be subject to CbCR are the following...more

Country by Country: Spain

The new Spanish Corporate Income tax Regulations were approved on 11 July 2015 through the Royal Decree 634/2015, which complement the provisions included in the Spanish Corporate Income Tax Law (Law 27/2014) that entered in...more

Country by Country: United Kingdom

Introduction - The UK CbC reporting regulations ("The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016") were made on 26 February 2016....more

Base erosion and profit shifting: Brazil proposes CbC reporting for multinationals - top points

The Brazilian Federal Revenue (RFB) has released the draft of a proposed Normative Rule (Public Consultation RFB No. 11/2016) regulating the implementation of country-by-country reporting via a CbC Report. The proposed draft...more

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

UK: when the Diverted Profits Tax and the expanded royalty withholding tax rules interact

Two ways in which the UK government has recently sought to increase the amount of tax payable in the UK by non-resident companies have been to impose a new Diverted Profits Tax (DPT) and to amend its existing 20 percent...more

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

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