On February 5, 2024, the French Supreme Tax Court (Conseil d’État) voided French tax authority guidelines from May 2023 that provided that shares acquired upon the exercise of founder stock options, or Bons de Souscription de...more
EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE -
On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more
6/6/2022
/ American Bar Association (ABA) ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Taxes ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
EU ,
European Commission ,
GILTI tax ,
Investigations ,
Member State ,
Model Rules ,
OECD ,
Pillar 2 ,
Sustainability ,
Tax Rates ,
White Collar Crimes
INTRODUCTION TO US TAXATION OF NFTS -
Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more
5/5/2022
/ Asset Management ,
Buyers ,
Charitable Donations ,
Corporate Taxes ,
Cross-Border ,
Donations ,
EU ,
Foreign Tax Credits ,
Germany ,
GILTI tax ,
Global Market ,
Income Taxes ,
International Tax Issues ,
Investment ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Pay-for-Performance ,
Remote Working ,
Sellers ,
Trustees ,
U.S. Treasury ,
UK ,
Withholding Tax
The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more
WHAT IS THE AIM OF PILLAR 2 RULES?
The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework’s project is to ensure that multinational groups of companies pay a minimum level of tax...more
Join us on August 26, 2021 for a virtual event held jointly by Fangda Partners (China) and McDermott Will & Emery (US and Europe). In this webinar we will be focusing on different controls on Chinese outbound investments from...more
In a landmark decision of 11 December 2020 involving digital player Conversant (fka Valueclick), the French Supreme Tax Court (Conseil d’État) ruled that a French company can qualify as a dependent agent, and thus as a French...more
The French Supreme Tax Court (Conseil d’État) ruled that the French withholding tax on the capital gain derived from the disposal of a substantial shareholding in a French company by a non-resident company is not compliant...more
The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more
2/11/2020
/ Appeals ,
Audits ,
BEPS ,
Corporate Counsel ,
Corporate Taxes ,
Criminal Prosecution ,
EU ,
Foreign Subsidiaries ,
France ,
Google ,
Ireland ,
Non-Prosecution Agreements ,
OECD ,
Popular ,
Principal Place of Business ,
Search & Seizure ,
Settlement ,
Tax Authority ,
Tax Evasion ,
Tax Treaty ,
Value-Added Tax (VAT)
A recent McDermott round table on European health private equity generated key insights into the future of medtech, digital health, and data analytics, and identified opportunities for companies and investors.
Digital...more
12/20/2019
/ CFIUS ,
Digital Health ,
Digital Services Tax ,
Global Dealmaking ,
Healthcare ,
International Arbitration ,
Life Sciences ,
Medical Devices ,
Outbound Transactions ,
Private Equity ,
State-Owned Enterprises ,
UK Competition and Markets Authority (CMA)
Governments are starting to catch up with online businesses. Multinational clients that provide online advertising services, sell consumer data, or run online intermediary platforms should prepare themselves for the imminent...more
11/13/2019
/ Business Taxes ,
Data Protection ,
Digital Service Providers ,
Digital Services Tax ,
Double Taxation ,
Imports ,
Income Taxes ,
International Tax Issues ,
Jurisdiction ,
Online Advertisements ,
Online Marketplace ,
Online Platforms ,
Personal Data ,
Reimbursements ,
Retaliatory Tariffs ,
Search Engines ,
Social Media ,
Tax Planning