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International Trade Business Organization Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.

Proposed Tax Regulations Address International Aspects of the New Partnership Audit Regime

by Alston & Bird on

We are about to witness an almost unprecedented centralized partnership audit regime that takes full effect for taxable years starting on or after January 1, 2018, as adopted in late 2015 by Section 1101 of the Bipartisan...more

State Aid in Disguise?—EC Investigates UK Tax Regime

by Jones Day on

The Background: The European Commission has opened an in-depth investigation into a specific provision of the UK-controlled foreign company rules. The Issue: The Commission will investigate whether the UK's so-called Group...more

EU Blacklisting of Tax Havens

by Ropes & Gray LLP on

After months of screening global tax policies by the European Council’s Code of Conduct Group, the EU has finalised its tax-haven blacklist – a list of non-cooperative jurisdictions for tax purposes, which currently comprises...more

In Case You Missed It: Launch Links - December, 2017

by WilmerHale on

Some interesting links we found across the web this week: Is Your Startup Prepared for the GDPR? - During last month’s QuickLaunch University webinar, Partners Dr. Martin Braun and Dave Gammell discussed data privacy...more

Five Things to Know about the Tax Cuts and Jobs Act

Even with the bill still in Conference, here are some things businesses should follow closely. Both House and Senate Bills call for deemed repatriation of accumulated foreign profits at reduced tax rates. ...more

The Senate’s New Base Erosion Tax: Highlights for Renewable Energy

by McDermott Will & Emery on

On December 2, 2017, the Senate approved its version of the Tax Cuts and Jobs Act. The Senate Bill includes the base erosion and anti-abuse tax, a new tax intended to apply to companies that significantly reduce their US tax...more

Amendments to Poland's Income Tax Laws Effective Jan. 1, 2018

by Miller Canfield on

Poland recently amended its Corporate Income Tax law, effective Jan. 1, 2018. The Polish Government announced that the objectives of the amendment are to ensure that taxes paid by large companies, especially multinational...more

Senate Passes Tax Reform Bill

by Dechert LLP on

The U.S. Senate passed its version of the GOP tax reform bill, the Tax Cuts and Jobs Act (the “Senate Bill”), on Saturday, December 2, 2017. Shortly before approving the Senate Bill, the U.S. Senate adopted a Manager’s...more

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

by Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

Deemed Dividends Under Proposed Tax Reform

by Miles & Stockbridge P.C. on

2017 tax reform efforts may alleviate adverse deemed dividend tax treatment of foreign subsidiary support for the obligations of U.S. parent companies. Present support is limited to the pledge of 66 ?rds of the stock in...more

State Income Tax Implications of Base Broadening Components of House and Senate Tax Reform Bills

by McDermott Will & Emery on

While there are differences between the House and Senate tax reform bills that remain to be worked out between the two chambers, both bills are positioned to broaden the tax base and reduce the tax rate. This article...more

Information Reporting For The Foreign-Owned Not-So-Disregarded Disregarded Entity

by Farrell Fritz, P.C. on

As the taxable year ending December 31, 2017 approaches, the thoughts of most people turn to holidays and family gatherings, feasting and celebrations, and reflecting, perhaps, on another year gone-by. Not so for tax...more

Australian Tax Update

by DLA Piper on

Introduction and overview The Australian Treasurer, The Hon Scott Morrison MP, on Friday 24 November 2017, released exposure draft legislation to prevent entities that are liable to Australian income tax from avoiding...more

Insight on Estate Planning - Year End 2017

In This Issue: - When should you turn down an inheritance? - Addressing intellectual property requires careful estate planning - Year end is an ideal time to review your estate plan - Estate planning pitfall: You’re...more

EU Opens Investigation Into UK Tax Scheme for Multinationals

by Bryan Cave on

The EU State aid rules are designed to stop Governments and local authorities giving companies a selective advantage, as doing so would create an unequal playing field. Say for example, a competitor in one country was given a...more

UK Tax Round Up - November 2017

by Proskauer Rose LLP on

UK Tax News and Developments - The OTS publishes its report "Value added tax: routes to simplification" - On 7 November, the Office of Tax Simplification (OTS) published its first report on VAT, which included a range...more

Infamy and Public Shaming: The newest risk of using "offshore" entities - What investors, companies and high-net-worth...

by Dentons on

While many companies and businesspeople actively manage their online and social media presence – many overlook the reputational impact of their financial and tax planning decisions. The recent “Paradise Papers” leak...more

Tax Reform Executive Summary – A 2-Pager on the 7 Things You Need to Know

Tax reform efforts, if successful, will have a major impact on virtually every business. There has been a great deal of reporting on the tax reform process and the proposed changes to the US Internal Revenue Code (IRC). This...more

How Proposed Tax Reform Will Impact Private Equity

by Foley & Lardner LLP on

Both the House of Representatives and the Senate have proposed their own versions of tax reform (the “House Proposal” and “Senate Proposal”, respectively, and together, the “Proposals”) which will drastically change the...more

Facilitating tax evasion: how to avoid being unwittingly caught by the Criminal Finances Act 2017

by White & Case LLP on

The Criminal Finances Act 2017 came into force on 30th September 2017. It has introduced a new corporate criminal offence of failing to prevent tax evasion. This new offence is aimed at companies who have failed to put in...more

Worldwide Territoriality: International Tax Proposals Broaden the Base

On November 16, 2017, the House of Representatives passed a much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (the House Plan), which was first introduced on November 2, 2017. The passage of the House Plan...more

China tax incentives for advanced technology service enterprises rolled out to the entire nation: key features

by DLA Piper on

The China tax incentives for Advanced Technology Service Enterprises (ATSE) were first introduced in the Suzhou Industrial Park in 2006, then applied to 21 pilot cities in 2014, and subsequently expanded to another 11 cities...more

UK Autumn Budget 2017 – the key measures impacting business

by White & Case LLP on

The Chancellor, Philip Hammond, has announced the Autumn Budget 2017. Alongside the headline-grabbing abolition of SDLT for first-time buyers on homes up to £300,000, and on the first £300,000 of properties up to £500,000,...more

UK To Tax Non Residents On Real Estate Gains

by Goodwin on

In a surprise announcement, the UK government announced its intention to start taxing non-UK residents on capital gains from UK real estate assets, including interests in “property rich” companies and other entities. The new...more

U.K. Is to Tax Gains Made by Non-Residents on Commercial and Residential Real Estate and Introduce Corporation Tax for Certain...

by King & Spalding on

The U.K. has announced that, from April 2019, tax will be charged on gains made by non-residents on disposals of all types of UK real estate, extending existing rules that apply only to residential property. The proposals,...more

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