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Corporate Taxes Foreign Investment

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

Possible Favorable Impacts on Inbound U.S. Real Property Investments under the Proposed Tax Act

by Charles (Chuck) Rubin on

The proposed Act has provisions that will provide benefits to non-U.S. persons making investments into U.S. real property. For foreign persons investing individually (or through pass-through entities) in U.S. partnership...more

Proposed U.S. Tax Reform May Impact Investments in U.S. Real Estate

by Mintz Levin on

Last week, the long-awaited proposed bill for a comprehensive reform of the U.S. tax code (the “Proposed Tax Reform”) was finally released. While the Proposed Tax Reform is likely to be heavily negotiated further and possibly...more

Tax Plan in Coalition Agreement Cabinet Rutte III (Dutch)

by Dentons on

Tax aspects of the 2017-2021 Government Agreement for Business - On October 10, the Cabinet Rutte III presented its government agreement for the next 4 years. Hereafter we discuss the most eye-catching fiscal aspects of...more

M&A Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more

French Elections Pave Way for Labor, Tax Reforms

In the months following the election of President Emmanuel Macron, who is perceived as pro-business, as well as a parliamentary election in which the new president’s party won the majority, companies and entrepreneurs have...more

Tax Court Holds That Foreign Corporation’s Sale Of A Partnership Interest Not Taxable In US

by Cole Schotz on

The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more

AFRICA - A Legal Guide for Business Investment and Expansion: Zimbabwe

1 .What role does the government of Zimbabwe play in approving and regulating foreign direct investment? The Government established the Zimbabwe Investment Authority (ZIA) to promote, coordinate and approve investment...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tanzania

1 .What role does the government of the United Republic of Tanzania play in approving and regulating foreign direct investment? The government plays an active role in approving and regulating foreign direct investment....more

AFRICA - A Legal Guide for Business Investment and Expansion: Nigeria

1 .What role does the government of nigeria play in approving and regulating foreign direct investment? Due to the economic benefits that accompany Foreign Direct Investment (FDI), the Nigerian government strives to...more

China implements new tax and administrative measures to boost foreign investment

by DLA Piper on

The Standing Committee of the China State Council, in their meeting of 28 July, released a strong signal on the encouragement of foreign investment in China. The meeting resulted in several particular measures aiming to...more

AFRICA - A Legal Guide for Business Investment and Expansion: Kenya

1. What role does the government of Kenya play in approving and regulating foreign direct investment? There is no regulation on foreign direct investment in Kenya except in specific sectors where state corporations have a...more

Foreign Investment in Australia - Update

by DLA Piper on

Foreign investment is key to Australia’s economic development, and Australia welcomes it. As the fourth largest economy in the dynamic Asia Pacific region, Australia's competitive economy is set for continued expansion -...more

AFRICA - A Legal Guide for Business Investment and Expansion: Ghana

1. What role does the government of Ghana play in approving and regulating foreign direct investment? The Government of Ghana continues to promote foreign direct investment in Ghana. In 2013, the Ghana Investment Promotion...more

AFRICA - A Legal Guide for Business Investment and Expansion: Egypt

1 .What role does the government of Egypt play in approving and regulating foreign direct investment? Egypt has traditionally been a leader in the Arab world in the political, cultural, and economic spheres. Due to recent...more

Tax Planning for Investment Into the United States Through Hybrid Entities - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more

AFRICA - A Legal Guide for Business Investment and Expansion: Angola

1. What role does the government of Angola play in approving and regulating foreign direct investment? Foreign direct investment is a highly-regulated sector in Angola. In August 2015, the Angolan Government enacted Law...more

Tax Court Rejects IRS’ Position in Rev. Rul. 91-32

Grecian Magnesite Mining, a Greek corporation (GMM), owned an interest in Premier Chemicals LLC, a Delaware limited liability company classified as a partnership for US income tax purposes (Premier). Premier conducted a trade...more

Trends in cross-border real estate investment and the changing tax landscape

by Hogan Lovells on

Real estate markets in both the U.S. and Europe continue to attract significant overseas investment. With interest rates at or near all-time lows, and dwindling returns in other asset classes, real estate has emerged as...more

2017 commercial real estate outlook: The impact of U.S. tax reform - April 2017

by Hogan Lovells on

Despite strengthening market headwinds and troubling political uncertainties, the U.S. commercial real estate market is likely to remain the top destination for global real estate capital in 2017, and may even see a return to...more

China Tax Newsletter - January / February 2017

by DLA Piper on

Welcome to the latest issue of our Tax Newsletter. In the past two months, there are a number of developments in the tax world in the PRC and Hong Kong. In the PRC, the State Administration for Industry and Commerce...more

Tax Considerations For The Closely-Held Foreign Investor In U.S. Real Property – Part II

by Farrell Fritz, P.C. on

Aside from planning for the taxation of U.S.-sourced rental income, the foreigner must plan for the disposition of the USRP pursuant to a sale. The taxation of gain realized by a foreigner on the sale of an interest in...more

Tax Considerations For The Closely-Held Foreign Investor In U.S. Real Property – Part I

by Farrell Fritz, P.C. on

Over the last few years, we have received an ever-increasing number of inquiries from “foreigners” who are interested in acquiring U.S. real property (“USRP”). Some of these foreigners – meaning closely-held business...more

Further Update on Federal Taxation - Australian Infrastructure Investment and Privatisation

by Jones Day on

Last month, we reported in our White Paper on taxation proposals directed at infrastructure and utility privatisation transactions. Since we wrote, the Commonwealth Treasury ("Treasury") has published a policy paper directed...more

EuroResource—Deals & Debt - March 2017

by Jones Day on

For the benefit of our clients and friends investing in European distressed opportunities, our European Network is sharing some current developments...more

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