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Withholding Tax Anti-Avoidance

International Lawyers Network

Establishing a Business Entity in Romania (Updated)

1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother company,...more

International Lawyers Network

Establishing A Business Entity In Romania (Updated)

1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother company,...more

Freeman Law

International Tax Treaty: China

Freeman Law on

Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Freeman Law

International Tax Treaty: Canada

Freeman Law on

Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

Bennett Jones LLP

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

Bennett Jones LLP on

On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more

Bennett Jones LLP

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

Bennett Jones LLP on

On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

Proskauer Rose LLP on

EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more

White & Case LLP

New Polish Tax Reforms Bring Much-Needed Structural Certainty Allowing Direct Issuances by Polish Issuers

White & Case LLP on

European Leveraged Finance Alert Series: Issue 1, 2019 - New Polish laws, effective 1 January 2019, have reformed the tax treatment of a number of different taxable business activities. In particular, the Ministry of...more

Hogan Lovells

Draft tax legislation for 2017 released

Hogan Lovells on

Following the 2017 Budget presented before Parliament on 22 February 2017, the draft tax legislation for the specific tax proposals was released on 19 July 2017 for comment. Comments should be made by 18 August 2017. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Insights: Brexit"

On June 23, the UK electorate took the historic decision to leave the European Union, a process that has never been undertaken by any member state. While the vote itself does not trigger the process of exit from a legal...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

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