News & Analysis as of

Withholding Tax Subsidiaries

Dorsey & Whitney LLP

Plan Ahead to Reduce (or Eliminate) U.S. Withholding Tax when Selling or Transferring U.S. Subsidiaries holding U.S. Real Property

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Many Canadian companies and individuals own U.S. real property interests through a U.S. corporation. The Foreign Investment in Real Property Tax Act (“FIRPTA”) regime imposes a withholding tax (currently at a rate as high as...more

Holland & Knight LLP

Breaking the "Equity Wall": Proposed Regulations Limit Chances to Minimize U.S. Withholding Tax

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The U.S. Department of the Treasury (Treasury) issued proposed regulations (the Proposed Regulations) on April 8, 2020, that would restrict foreign persons' ability to minimize U.S. tax through "conduit" financing...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

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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

McDermott Will & Emery

CJEU Rules on Parent-Subsidiary & Interest and Royalties Directives Anti-abuse Clauses

On February 26, 2019 the Court of Justice of the European Union (CJEU) issued the long-awaited judgments on the cases concerning the Danish government withholding tax on dividends and interest paid by Danish companies to...more

Latham & Watkins LLP

Tax Exemption Offers Relief in the German Restructuring Market

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German legislator introduces tax exemption for income resulting from debt waivers in restructuring scenarios with retroactive effect. On 23 November 2018, the German legislator approved legislation regarding tax exemption...more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

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President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Dorsey & Whitney LLP

Common U.S. Tax Withholding and Reporting Errors with Respect to Certain RSUs

Dorsey & Whitney LLP on

A Canadian company (the employer) historically has not issued equity-based awards to employees of its U.S. subsidiaries, but it now is considering doing so. Past posts have addressed potential U.S. income tax pitfalls and the...more

Akin Gump Strauss Hauer & Feld LLP

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

Nutter McClennen & Fish LLP

Amid the Economic Uncertainties of the Brexit, New Challenges in Corporate Tax Structuring for UK Companies (And Their Parents,...

The June 23, 2016 “leave” Brexit vote has left many in the business and legal communities stunned, and while uncertainties abound, there is no doubt that wading through the economic and administrative complexities of exiting...more

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