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Tax Treaty Dividends

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

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

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

Final Regulations Under Section 871(m) Clarify Withholding Tax Rules for Equity-Linked Derivatives, Yet Many Challenges Remain

by Shearman & Sterling LLP on

On September 17, 2015, the Treasury Department and the Internal Revenue Service (the “IRS”) issued new temporary and final regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

Use of Estonia in U.S. International Tax Planning

by 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

Planning For Qualified Dividend Income When Taking Foreign Companies Public - Tax Update Volume 2015, Issue 2

by Pepper Hamilton LLP on

Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income...more

IRS Denies Treaty Benefits Despite Lack of Treaty Shopping

by Bilzin Sumberg on

In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from...more

Retroactive Tax Planning

by Bilzin Sumberg on

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

by Bilzin Sumberg on

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more

Favorable IRS ruling for US taxpayer on application of US - Cyprus tax treaty

by DLA Piper on

In a recent internal legal memorandum (the ILM), the IRS concluded that a US individual was entitled to treat dividends received from a Cypriot holding company with no Cypriot ownership as qualified dividend income (QDI), and...more

Tax Newsletter - Second Edition 2013: A Review Of PRC And Hong Kong Tax Developments

by DLA Piper on

In This Issue: *CHINA: - HEADQUARTER AND BRANCHES VAT FILING UNDER THE VAT PILOT PROGRAM - FURTHER CLARIFICATION ON BENEFICIAL OWNERSHIP OF DIVIDENDS UNDER DTA WITH HONG KONG - PE ON SECONDMENT...more

2013 Amendments to United States and Japan Income Tax Treaty

by Baker Donelson on

On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more

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