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BEPS

Whiteford

Client Alert: The Maryland Department of the Environment Publishes New Proposed Building Energy Performance Standards That Would...

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On September 6th, the Maryland Department of the Environment (“MDE”) officially withdrew the proposed regulations it had previously issued in December 2023, creating statewide Building Energy Performance Standards (“BEPS”)...more

Goodwin

Proposed Amendments to Pillar Two Law in Luxembourg

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On 12 June 2024, Luxembourg published a bill of law amending the law of 22 December 2023 (the Pillar Two Law[1]) implementing EU directive no. 2022/2523, largely known as the “EU Minimum Tax Directive” or “Pillar Two...more

Ballard Spahr LLP

New Prince George's County Rent Control Legislation and Other Updates

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Our prior Alert discussed the Prince George’s County temporary extension of rent control, Montgomery County rent control updates and the much-anticipated rent control regulations, rental license fee increases, new housing...more

Ballard Spahr LLP

Prince George's County Rent Control Extension/BEPS/Montgomery County Rent Control Updates

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Our recent Alert focused on the D.C. Housing in Downtown program, the Montgomery County Right of First Refusal legislation, rent control in Montgomery and Prince George’s Counties, the SCOTUS rent control challenge denial,...more

Conyers

Guiding Captives Through Global Developments

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Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more

Jones Day

Maryland to Propose Building Energy Performance Standards

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The Maryland Department of the Environment ("MDE") will publish proposed rules limiting greenhouse gas ("GHG") emissions from covered buildings and requiring covered building owners to submit detailed energy performance...more

Ballard Spahr LLP

November Multifamily Alert

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As a follow-up to our recent alert, here are some updates on regional and national legislative activity impacting real estate...more

Stikeman Elliott LLP

Tax Base Erosion: Canada Responds with Draft EIFEL Rules Legislation

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On August 4, 2023, the Department of Finance released an updated version of the draft legislation that will incorporate the excessive interest and financing expense limitation rules (“EIFEL Rules”) into the Income Tax...more

Holland & Knight LLP

New Multilateral Tax Treaty Implements the Subject to Tax Rule

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More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more

Eversheds Sutherland (US) LLP

Bermuda corporate income tax consultation: impact on reinsurance agreements

Bermuda has announced that it is considering the implementation of a new corporate income tax regime to be effective on or after January 1, 2025, in response to the OECD’s BEPS Pillar II global minimum tax rules. The...more

Holland & Knight LLP

Entra en vigor el Convenio Multilateral para Tratados Tributarios en México

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Se publicó en el Diario Oficial de la Federación (DOF) de México el decreto por el que se promulga el Convenio Multilateral para Implementar las Medidas Relacionadas con los Tratados Fiscales para Prevenir la Erosión de las...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

Morgan Lewis

The Dawn of BEPS 2.0 in Singapore: An Uncertain Road, A Certain Destination

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The global wave of the two-pillar solution to address base erosion and profit shifting, commonly known as BEPS 2.0, has formally washed ashore in Singapore. It is now certain that multinational enterprises (MNEs) with local...more

Goodwin

Luxembourg Draft Budget Law 2023: The Most Awaited Reverse Hybrid Clarification

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​​​​​​​On 12 October 2022, the finance minister presented the Luxembourg budget bill for fiscal year 2023. For corporate tax payers, and particularly for funds, there is a most welcomed clarification on the scope of the...more

Holland & Knight LLP

Ratificación del Convenio Multilateral para Tratados Tributarios en México

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Se programó una reunión de trabajo de las Comisiones Unidas de Relaciones Exteriores y de la Secretaria de Hacienda y Crédito Público de México el 6 de octubre de 2022, para la discusión y en su caso aprobación de los...more

Paul Hastings LLP

Tax Avoidance or Not: Restructuring of Multinational Group Companies with use of Intra-group Loan — Deductibility of Interest...

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Transactions within a corporate group can sometimes achieve reduction of tax obligations, regardless of whether or how much such result was intended. One typical way observed is to extend an international intra-group loan by...more

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

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International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Freeman Law

Country-by-Country Reporting

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In recent years, tax authorities across the globe have adopted a number of OECD-led initiatives aimed at curbing the ability of multinational enterprises to engage in so-called Base Erosion and Profit Shifting (BEPS) (i.e.,...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Miller Nash LLP

When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)

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The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more

Proskauer - Tax Talks

A step closer to agreement on taxation of the digital world

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On 8 October 2021, the OECD released a further statement in relation to the BEPS 2.0 proposals, aimed at addressing taxation of the modern digital economy. This is the latest development in the attempts to more equally share...more

Foster Garvey PC

Global Tax Reform Takes a Major Step Forward as 136 Nations Sign on to OECD BEPS 2.0 Framework

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On Friday October 8, 2021, the Organization for Economic Cooperation and Development (OECD) announced that 136 Nations, including the United States and the rest of the G20, have signed on to the OECD/G20 Inclusive Framework...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

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Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Smith Gambrell Russell

The OECD Two-Pillar Plan: A Joint Solution to a Global Tax Problem

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According to the OECD Secretary-General Report to G20 Finance Ministers dated July 1, 2021 (OECD Report), 130 member jurisdictions of the G20/OECD Inclusive Framework on BEPS (Base Erosion and Profit Shifting), representing...more

Cadwalader, Wickersham & Taft LLP

An(other) OECD BEPS 2.0 Update

The release of the Pillar One and Pillar Two “blueprints” in October 2020, and the recent G7 (June 2021) and G20 (July 2021) meetings, provided an opportunity for further progress to be made on the Pillar One and Pillar Two...more

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