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Royalties Tax Planning

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

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On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Freeman Law

U.S. and Mexico | Trademark Royalties and Tax Considerations

Freeman Law on

Approximately 30% of the global market is related to intellectual property. While intangible goods cannot be touched or seen, they are all too real. For companies around the world, one of the most important intangible assets...more

Skadden, Arps, Slate, Meagher & Flom LLP

Navigating the Once-Obscure German Nonresident Withholding Tax

In this episode of Skadden’s “GILTI Conscience” podcast, partners Nate Carden and David Farhat discuss the German nonresident withholding tax with partner Johannes Frey, in the Frankfurt office, and Ryan Lange and Kerim Keser...more

Eversheds Sutherland (US) LLP

German withholding tax on royalty payments between non-German parties - German tax authorities confirm position on withholding...

On February 11, 2021, the German Federal Ministry of Finance (GFMF) published a decree (the Decree), confirming their position that German withholding tax (at a rate of 15.825%) is due and payable on gross royalties that are...more

Foodman CPAs & Advisors

Payers and Payees have Obligations to Comply with Backup Withholding

Foodman CPAs & Advisors on

Backup Withholding requires a payer to “withhold tax” from payments that are not otherwise subject to withholding.  A Taxpayer (payee) may be subject to Backup Withholding if it...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Lewitt Hackman

Why Yesterday's SCOTUS Decision May Impact Franchisor Royalties

Lewitt Hackman on

Yesterday, in South Dakota vs. WayFair, Inc., et al., the United States Supreme Court (“Court”) overturned long-standing precedents that required an out-of-state Seller to have a physical presence in a state to collect...more

Carlton Fields

Tightening the Tax Screws on International IP Structures

Carlton Fields on

For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more

Carlton Fields

U.S. Pre-Immigration Tax Planning

Carlton Fields on

The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

Bilzin Sumberg

Use of Estonia in U.S. International Tax Planning

Bilzin Sumberg on

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

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