News & Analysis as of

Cross-Border Corporate Taxes

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

McDermott Will & Emery

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Proskauer - Tax Talks

COVID-19: DAC 6 reporting delayed

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In light of COVID-19, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative...more

Holland & Knight LLP

Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses

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The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more

Proskauer Rose LLP

UK Tax Round Up - December 2018

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UK Developments - Taxpayer succeeds in judicial review case against HMRC - On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK)...more

Bracewell LLP

Focus on Finance: Tax Reform and the Banking Industry Revisited

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The Tax Cuts and Jobs Act (TCJA) has far-reaching implications for the banking and finance industry. In our very first Bracewell Tax Report, we noted certain issues that companies might consider when evaluating their...more

Proskauer Rose LLP

UK Tax Round Up - August 2018

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VAT treatment of supplies of non-employed temps clarified - A recent Court of Appeal case – Adecco v HMRC – clarifies a longstanding question over seemingly contradictory case law on the VAT treatment of employment agency...more

Proskauer Rose LLP

UK Tax Round Up - April 2018

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General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more

Dechert LLP

Asset Management Regulatory Roundup - April 2018 - Issue 7

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A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details of the FCA’s statement on the implementation period for Brexit; the requirement for firms...more

Proskauer Rose LLP

UK Tax Round Up - March 2018

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Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more

Proskauer Rose LLP

UK Tax Round Up - February 2018

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Case law developments - Settlement payment not deductible as an expense of a trade (Vaines v HMRC) - Mr. Vaines was a solicitor. In the 2007/08 tax year he paid a settlement amount to a third party that had made a...more

Foodman CPAs & Advisors

Cumplimiento Fiscal Internacional

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Hogan Lovells

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

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Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

Jones Day

EuroResource—Deals & Debt - March 2017

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

Holland & Knight LLP

U.S. Treasury Tries to Clamp Down on Tax Inversions

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Lately, the media has focused on tax inversions, most recently when Burger King announced that it will purchase Tim Hortons, a Canadian company, but what are they?...more

Dechert LLP

The New Landscape for Inversions: IRS and Treasury Change the Rules

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The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more

Latham & Watkins LLP

Treasury Announces Inversion Regulations; Reach Extends to Other Cross-Border M&A

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New guidance seeks to curb the incidence of inversions and reduce the associated tax benefits, but also extends beyond inversions. On September 22, 2014, the US Department of the Treasury (Treasury) and the Internal...more

K&L Gates LLP

EU Adopts a Parent-Subsidiary Directive Amendment on Hybrid Loans

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On July 8th 2014, the European Union’s Economic and Financial Affairs Council (ECOFIN) adopted an amendment to the Parent-Subsidiary Directive (PSD). This amendment is targeted at cross-border hybrid loans and aims to...more

Goulston & Storrs PC

Cross-Border Interest Expense Apportionment Regulations Finalized

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The IRS issued cross-border interest apportionment final regulations. These adopt the approach from the 2012 temporary regulations, requiring a 10% corporate partner to apportion its interest expense by reference to the...more

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