AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
In this episode, Mike Burke, AGG Corporate partner and leader of the Ireland & Northern Ireland practice, explores U.S. tax considerations for foreign businesses scaling to the U.S., including issues such as the branch...more
Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more
My VC Fund has U.S. and non-U.S. General Partners, will I need to file CFIUS declarations for every investment I want to make in tech, in infrastructure, or in a company with customers’ personal data? This is a critical...more
Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan with respect to base erosion...more
• Mandatory declarations of certain transactions now required • Certain changes to pre-existing regulations also announced and effective immediately • Mandatory declaration requirement may not ease burden on parties...more
Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more
The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more
The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more