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

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

The Taxation (Cross-border Trade) Bill and trading under WTO rules

by DLA Piper on

The Taxation (Cross-border Trade) Bill was introduced in the House of Commons on 20 November 2017. It will have to be passed by both Houses before it becomes law, and, as with other key pieces of Brexit legislation, including...more

E.U. Financial Leaders Respond To The Proposed U.S. Tax Plan

by Fox Rothschild LLP on

Some of the most important trade partners of the U.S. are raising concerns about the proposed U.S. plan to overhaul its tax code. The finance ministers of Europe’s five largest economies voiced concerns about the tax plan in...more

What's New In Washington - December 2017

December is often the busiest time in Washington, and this year is no different as Congress races toward the holiday finish line. There is still a multitude of problems to solve before members can head back to their...more

Proposed UK Real Estate Tax Regime Targets Offshore Investors' Capital Gains

by Jones Day on

The Situation: Historically, the United Kingdom has not taxed capital gains on real estate disposals when the seller was not a UK resident. The Development: Coming into line with most of the world's jurisdictions, the UK...more

Major tax bill clears U.S. Senate by 51-49 margin, Part I

by Moskowitz LLP on

A 500-page long Republican tax bill, with numerous and significant last minute changes – as well as some illegible handwritten edits in the margins – cleared the U.S. Senate in the early hours of Saturday morning, by a 51-49...more

IRS Signals Intent to Aggressively Pursue Undisclosed Offshore Accounts

by Varnum LLP on

At the recent National Institute on Criminal Tax Fraud and Tax Controversy, senior IRS and Department of Justice (Tax) officials sounded the proverbial warning alarm to taxpayers with undisclosed or offshore financial...more

EU “Black Lists” Bahrain and UAE as Non - Cooperative Jurisdiction for Tax Purposes

by King & Spalding on

On 5 December 2017, the Economic and Financial Affairs Council (ECOFIN) determined a list of 17 non-cooperative jurisdictions, which included Bahrain and the United Arab Emirates (UAE). This list was established based on...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

U.S. v. Coinbase: Virtual Currency Holders Not Outside the IRS’s Reach

by Dechert LLP on

The U.S. District Court for the Northern District of California, on November 28, 2017, ordered the international digital currency broker, Coinbase, Inc., to produce to the Internal Revenue Service (IRS) the records of...more

France Announces Its First Deferred Prosecution Agreement

In a move that could signal a new phase of government enforcement in France, on November 27, 2017, French authorities published a Convention judiciaire d’intérêt public (CJIP) with HSBC Private Bank Suisse SA (HSBC PB), the...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

DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters

At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

by Proskauer - Tax Talks on

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more

U.S. Tax Reform in Final Stretch

by Hogan Lovells on

This past week, on 1 December, the Senate voted 51-49 to advance its version of U.S. tax reform legislation. This sets the stage for a conference committee process to occur over the next two weeks, in which the Senate and...more

Federal Tax Reform: An Analysis of the House and Senate Bills

by Ballard Spahr LLP on

As we are sure you know, both the U.S. House of Representatives and Senate have passed their own versions of tax legislation, known as the Tax Cuts and Jobs Act. The two different bills will be reconciled in a conference...more

Estate Planning Pitfall - You’re retiring to a foreign country

If plans call to relocate to another country after retirement, be aware that they may be tarnished if a person doesn’t look into all potential estate tax and income tax implications first. This brief article explores three...more

Federal Tax Reform: Side-by-Side Comparison of the Senate and House Approved Bills, Plus the Big Picture

by Ballard Spahr LLP on

Last updated December 5 - The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill,...more

Senate Advances Tax Reform Bill

by Morrison & Foerster LLP on

On December 2, 2017, the Senate passed its version of tax reform legislation (the "Senate Bill"), advancing it to the next stage. While the House of Representatives passed its version of tax reform (the "House Bill") on...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

Tax Alert Regarding The Impact Of The House And Senate Tax Bills On International Taxation

On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced a tax bill entitled the Tax Cuts and Jobs Act, and later proposed amendments to the bill on November 3, November 6, and November 9,...more

Did The Paradise Papers And Panama Papers Play A Role In The GOP Tax Plan?

by Ifrah PLLC on

Congress is poised to deliver on tax reform this year. As part of the package, both houses are seeking to encourage the repatriation of trillions of dollars that corporations and wealthy individuals have been stockpiling...more

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