Corporate Taxes, Tax Treaty, Dividends

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

Bilzin Sumberg on 9/28/2016

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

Brexit – The UK and International Tax Consequences

Dechert LLP on 7/2/2016

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

European M+A News, Winter 2016

Morrison & Foerster LLP on 2/11/2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

Use of Estonia in U.S. International Tax Planning

Bilzin Sumberg on 8/24/2015

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

IRS Denies Treaty Benefits Despite Lack of Treaty Shopping

Bilzin Sumberg on 10/9/2014

In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from...more

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Bilzin Sumberg on 6/6/2014

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more