News & Analysis as of

Tax Avoidance

The Australian Government significantly expands ATO powers to fight multinational tax avoidance: Legislation introduced for 40 per...

by DLA Piper on

The Australian Government introduced legislation (DPT legislation) into Parliament on 9 February 2017 to implement a further component (second limb) of the United Kingdom–style diverted profits tax (DPT), with effect from 1...more

Alignment with international standards

by Hogan Lovells on

In March, two notices were published in the Government Gazette prescribing regulations in respect of third party returns and the fixed penalty provisions that will be applicable in instances where there is non-compliance in...more

Report a Canadian Tax Evader and Make Money?

by Bennett Jones LLP on

Yes, it's possible. Canada has had a tax whistleblower program for four years, the Offshore Tax Informant Program (OTIP). The OTIP pays individuals who qualify for the program and provide information to the Canada Revenue...more

Automatic exchange of information and insurance companies - a question of compliance

by Hogan Lovells on

Automatic exchange of information (AEOI) regimes, primarily aimed at curbing tax avoidance through the use of foreign accounts and investment platforms, have recently become a global trend, starting with the adoption of the...more

Budget 2017

by Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

The Australian Government significantly expands ATO powers to fight multinational tax avoidance: Legislation introduced for 40 per...

by DLA Piper on

Introduction and overview - The Australian Government introduced legislation (DPT legislation) into Parliament on 9 February 2017 to implement a further component (second limb) of the United Kingdom–style diverted...more

IRS Labels Syndicated Conservation Easements as “Listed Transactions,” Adds Disclosure Requirements

by Arnall Golden Gregory LLP on

In a notice issued December 23, 2016, the IRS named certain syndicated conservation easements as “listed transactions,” a category of transactions which the IRS believes carry a strong potential for abusive tax avoidance....more

When Investing In A Partnership May Be A Tax Problem

by Farrell Fritz, P.C. on

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

Kentucky Court Of Appeals Slashes Punitive Award Against Grant Thornton

A couple of months ago, the Kentucky Court of Appeals in Grant Thornton LLP v. Yung cut a trial court’s award of punitive damages from $80 million to $20 million—reducing the punitive/compensatory ratio to 1:1....more

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

by DLA Piper on

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

UK Autumn Statement 2016

by White & Case LLP on

This was Chancellor Phillip Hammond's first (and last) Autumn Statement. From Autumn 2017, there will be an Autumn Budget for the coming year, which will enable greater scrutiny of complex tax provisions, followed by a Spring...more

Confirmation of Non Dom Changes in the UK Autumn Statement

by McDermott Will & Emery on

New UK Chancellor Philip Hammond gave his first Autumn Statement on 23 November 2016. Whilst there were no further details relating to the reforms of the taxation of non-UK domiciliaries and UK residential property, the...more

Treasury Issues Final Regulations Under Section 956

by Alston & Bird on

On November 3, 2016, the Treasury issued final regulations (T.D. 9792) that set forth guidance on when a controlled foreign corporation (CFC) has a deemed repatriation under Section 956 in ...more

Urgent Captive Insurance Alert: IRS Lists 831(b) Micro-Captives as “Transaction of Interest”

by Tucker Arensberg, P.C. on

On November 1, 2016, via Notice 2016-66 (2017-47 IRB) (link to notice), the Treasury Department and IRS declared certain captive insurance transactions under Code section 831(b) as “transactions of interest.” Commonly...more

Purchasers of NJ Tax Sale Certificates - What You Include in Your Proof of Claim Can Cause a Loss of Your Claim and Lien

by Dechert LLP on

In Princeton Office Park, the U.S. Court of Appeals for the Third Circuit affirmed the bankruptcy and district court rulings that the purchaser of a NJ tax sale certificate forfeited its claim and lien because it included the...more

Recent EU and Luxembourg anti-BEPS developments extending to third countries

by DLA Piper on

EU Commission's ATAD proposal released On 25 October 2016 the EU Commission presented yet another package of corporate tax reforms comprising, inter alia, a proposal on tackling "hybrid mismatches" between the tax...more

European Commission publishes an EU corporate tax system

by DLA Piper on

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

This Week In Securities Litigation

by Dorsey & Whitney LLP on

As the government fiscal year draws to an end, the Commission filed a series of enforcement actions. Those included two insider trading cases, an action alleging violations of the whistleblower provisions, another against a...more

Three Restatements Conclude with SEC Enforcement Action

by Dorsey & Whitney LLP on

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

Battle Heats Up Over Who Can Regulate Tax on International Companies

In a decision that again pits the United States against the European Union in that ongoing battle over which entity can primarily tax international business, Margrethe Vestager, the European Union commissioner for...more

CRA Provides OTIP Update

by Dentons on

The CRA’s Offshore Tax Informant Program (OTIP) was launched in January 2014. From the CRA’s webpage describing the program: Launched as part of the Canada Revenue Agency’s (CRA) efforts to fight international tax...more

Proposed Regulations under Section 355 Clarify Device and Active Trade or Business Requirements for Tax-Free Spin-offs

by Proskauer Rose LLP on

On July 15, 2016, the U.S. Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) published proposed regulations that would modify the device and active trade or business requirements for tax-free...more

Five key elements of the EU ATA Directive compromise

by DLA Piper on

In late June, the Economic and Financial Affairs Council of the European Union (ECOFIN or the Council) achieved political consensus on the content of the EU Anti-Tax-Avoidance Directive (the ATA Directive). In last month's...more

Brexit: Key Tax Implications for Alternative Investment Funds and Investment Managers

The result of the UK’s referendum of 23 June 2016 was announced today as a victory for ‘Brexit’ - in other words, for the UK to exit the European Union. This decision is expected to have significant ramifications for the...more

EU Council Agrees on Final Anti Tax Avoidance Directive

by Proskauer - Tax Talks on

We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

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