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Tax Treaty Corporate Taxes

September 2017: An Update on UK Tax Disputes Including the New UK Corporate Criminal Offense: What Is It and What Should You Do...

Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

Swiss-Domiciled Company Denied Treaty Benefits For Treaty Shopping

by Fox Rothschild LLP on

Statutory Background- When a foreign corporation receives dividends from U.S. sources, the income is generally subject to tax at 30%. To avoid double taxation and encourage cross-border investments, the U.S. has entered...more

Disallowance of Deduction for Interest Paid to Hungarian Affiliate Serves as a Reminder of Department’s Continued Audit Scrutiny...

by Reed Smith on

A case recently resolved at the Appellate Tax Board serves as a reminder that Massachusetts’ auditors continue to aggressively challenge the following intercompany transactions: - Interest deductions for interest paid to...more

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

Tax Planning for Investment Into the United States Through Hybrid Entities - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more

The UK Double Tax Treaty Passport Scheme – Changes for the UK Loan Market

by Morrison & Foerster LLP on

The UK Double Tax Treaty Passport (“DTTP”) scheme has recently been extended by HM Revenue & Customs (“HMRC”) to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme. The aim of the amendments is...more

Inbound and Outbound U.S. Tax Planning - What's Left After the MLI?

by Bilzin Sumberg on

On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place. ...more

More than 60 countries sign OECD multilateral convention to counter base erosion and profit shifting

by DLA Piper on

This week's signing ceremony for the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS marks a new and important milestone in the international tax agenda to tackle perceived abusive...more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Indirect sale of real estate in the Russian Federation in the context of the beneficial ownership rules

by Dentons on

On 17 January 2017 the Commercial Court of Vladimir Oblast delivered a judgement in case No. ?11-6602/2016 (the “Decision”) under the claim of Vladimir Energy RetailCompany1 Public Joint-Stock Company (the “Company”)....more

BEPS: Update on Action 6 on Treaty Benefits

by Proskauer - Tax Talks on

In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and...more

"Double Trouble": The Kenyan Constitution and DTAs

by Dentons on

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

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

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

by Bilzin Sumberg on

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

Brexit – The UK and International Tax Consequences

by Dechert LLP on

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

Washington ALJ Upholds B&O Assessment on German Company’s Royalty Income

by McDermott Will & Emery on

On May 31, 2016, the Washington Department of Revenue (DOR) Appeals Division released a Determination (No. 15-0251, 35 WTD 230) denying a German pharmaceutical company’s business and occupation tax (B&O) protest. The...more

International Crackdown: Tax Authorities Look to Employment Structures in Initiating Audits

In structuring their workforces abroad, taxes are a major driving force for employers—and if recent government initiatives are any indicator, employers should take care when considering the tax implications of their staffing...more

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

LLCs May Be Right Unless They’re Wrong

by Arnall Golden Gregory LLP on

As I’ve posted before, I usually advise non-US companies to form a corporation when expanding to the United States. Every now and then, I get some pushback because the non-US company has heard about ‘limited liability...more

UK Budget 2016: Finance

by DLA Piper on

From April 2017, the UK government is to cap the amount of corporation tax relief for interest to 30% of taxable earnings in the UK or the net interest to earnings ratio for the worldwide group. This is subject to a threshold...more

European M+A News, Winter 2016

by Morrison & Foerster LLP on

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

A Buyer’s Market for MLPs in 2016

by Gerald Nowotny on

Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the After-Tax Investment Return of Foreign Investors in MLPs - Overview - Master Limited Partnerships are publicly traded partnerships....more

Tax Newsletter - September/October 2015 (China & Hong Kong)

by DLA Piper on

Welcome to the latest issue of our Tax Newsletter. A number of developments have taken place in the PRC and Hong Kong that could be of legal and tax significance to your businesses. In the PRC, the State...more

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