Tax Avoidance

News & Analysis as of

IRS Issues More Anti-Inversion Rules

Following on its prior Notice 2014-52 anti-inversion guidance, the IRS has issued new Notice 2015-79 to further limit (i) inversion transactions that are contrary to the purposes of the Section 7874 anti-inversion rules and...more

European Competition Law Newsletter – November 2015

A company that helps with or facilitates a cartel is at just as much risk of sanctions and penalties as are the actual cartelists. This was confirmed by the EU’s highest court (the European Court of Justice (ECJ)) on 22...more

Tax Haven List Repealed by D.C. Council

After being in effect for only a week, the Council of the District of Columbia (Council) unanimously enacted legislation on November 3, 2015 that will repeal the list of tax haven jurisdictions specifically enumerated in the...more

Tax Evasion Vs. Tax Planning/Avoidance: Knowing The Difference Is Important

Last time, we began speaking about recent recommendations made by an international organization regarding tax avoidance which will reportedly make it harder for businesses to take advantage of tax law. As we noted, the...more

OECD Publishes Final BEPS Project Reports

A focus on hybrid arrangements, interest deductions, treaty abuse and permanent establishment structures. On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit...more

International Organization Addresses Issue Of Tax Avoidance

At the beginning of the week, the Organization for Economic Cooperation and Development—an international organization founded to advise industrial nations on economic policy—proposed a plan to address what has become an...more

Australian Tax Alert: Australia Pursues Multinational Tax Avoidance

In the context of the imminent release of the OECD report to G20 finance ministers (in October 2015) dealing with its final recommendations on the Base Erosion Profit Shifting (BEPS) Action Plan, Australia has introduced...more

Treasury and IRS Issue New Temporary Treasury Regulations

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more

Italian Tax Reform

The Italian Government has recently approved a new decree, which reshapes the definition of abuse of law and tax avoidance and changes the rules on the statute of limitations in the event of tax crimes. The decree also...more

The “Reed Amendment” and Admissibility to the United States: Will I Be Barred From Reentry After Renunciation?

A common concern about renunciation of U.S. citizenship is that of admissibility to the United States thereafter. Many people tell me that they have read about a permanent ban on reentry to the United States following...more

Lawsuit by U.S. Presidential Candidate Challenges the Constitutionality of FATCA

Senator Rand Paul, R-Ky., along with six current and former U.S. citizens living abroad, filed a lawsuit, July 14, in the U.S. District Court for the Southern District of Ohio challenging the constitutionality of the Foreign...more

The Budget comes but twice a year

One joy of UK Parliamentary democracy is watching the annual budget with its howling Government MPs, roaring Opposition MPs and ritual interventions of the Deputy Speaker to allow the Chancellor to finish off his speech....more

IRS Targets Use of Basket Option Contracts and Basket Contracts by Hedge Funds and Other Taxpayers as Tax Avoidance Transactions

On July 8, the Internal Revenue Service (IRS) issued two notices (Notice 2015-47, 2015-30 IRB 1, and Notice 2015-48, 2015-30 IRB 1) targeting the use of Basket Option Contracts and Basket Contracts as tax avoidance...more

Focus on Tax Controversy - Summer 2015

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

Changes to Non-Domiciled Status Announced in The UK Summer Budget 2015

Following the United Kingdom’s General Election in May, George Osborne, Chancellor of the Exchequer, gave the new government’s first budget speech on 8 July 2015. In his speech, Mr Osborne announced some changes to the tax...more

IRS Issues Notices Regarding Certain Structured Transactions

Parties that enter into “basket option contracts” and “basket contracts” should be aware that the IRS is likely to challenge such transactions and that they have a new obligation to report the transactions to the IRS or face...more

UK Summer Budget 2015 – Key Tax Measures

The Chancellor of the Exchequer’s first Budget of the new Parliament, delivered on 8 July 2015, will be remembered as a reforming Conservative budget, including significant changes to the United Kingdom’s welfare provisions...more

Australian Tax Update: Australian Budget 2015-2016

The Australian Government has released a measured but significant 2015-2016 Federal Budget. The three main tax changes include a focus on multinational tax avoidance by introducing new targeted non-resident anti-avoidance...more

China’s Tax Authority Issues New Circular to Regulate Payment to Overseas Affiliates

On July 29, 2014, the State Administration of Taxation (SAT) of the People’s Republic of China (PRC or China) released The Notice Regarding the Launch of Tax Anti-Avoidance Investigations on Remittance of Substantial Amounts...more

Corporate Alert: China’s New Tax Regulation on Indirect Disposals Complicates Certain Offshore M&A Deals

In 2009, China’s State Administration of Taxation (SAT) promulgated Circular 698 to empower PRC tax authorities to re-characterize transfers by non-PRC residents of shares in offshore companies that hold equity interests in...more

Google Tax Spreading to Other Countries?

In December of last year, the UK announced a 25% tax on US multinational companies that do business in the UK but avoid paying UK tax through careful tax planning (for example, through the use of tax treaties)....more

As Expatriations Increase, Potential Relief for “Accidental” U.S. Citizens

According to Treasury reports, 3,417 U.S. citizens relinquished their U.S. citizenship in 2014, which is more than the number of expatriations reported in prior years. As required by law, the Treasury publishes a quarterly...more

Tax Measures in the 2014 UK Autumn Statement

Announcements support UK growth and prevent tax avoidance. On 3 December, UK Chancellor of the Exchequer George Osborne made a number of tax-related announcements in the 2014 Autumn Statement. Given the government’s...more

Status Updates - November 2014 #13

Search stripped? European regulators have several beefs with Google—the digital giant has been accused of tax avoidance and violations of data protection laws—but right now they’re focused on whether the company, which...more

Addressing Portability

As we have discussed in previous newsletters, the concept of “portability” introduced in 2012 allows a surviving spouse to use the unused federal estate tax exemption of the first spouse to die, but only if a federal estate...more

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