News & Analysis as of

Dividends Double Taxation

Rivkin Radler LLP

New York Can Be Stingy Giving Credit – Resident Tax Credit, That Is

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The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more

Goodwin

Public Consultation on a Common EU-Wide System for Withholding Tax Claims on Dividend and Interest Payment

Goodwin on

The EU Commission published a public consultation based on its initiative to introduce a common EU-wide system for withholding tax on dividend or interest payments, which includes a system for tax authorities to exchange...more

Goodwin

New Protocol to Luxembourg-Russian Double Tax Treaty Set to Take Effect

Goodwin on

On 6 November 2020, Luxembourg and Russia signed a Protocol amending the Luxembourg-Russian Double Tax Treaty. This new Protocol provides new withholding tax rates and rules for the taxation of dividends and interest...more

White & Case LLP

Spanish Supreme Court confirms right to claim reimbursement of dividend withholding taxes by non EU Funds

White & Case LLP on

The Spanish Supreme Court has released a relevant decision regarding the taxation in Spain of dividends collected by non resident Investment Funds from Spanish distributing entities in whose capital they participate....more

Goodwin

New France-Luxembourg Double Taxation Treaty

Goodwin on

A new double taxation treaty between France and Luxembourg was signed on 20 March 2018 (the “New Treaty”). This New Treaty will replace the current tax treaty dated 1 April 1958, as amended several times and for the last time...more

A&O Shearman

A new double tax treaty about to be concluded between France and Luxembourg

A&O Shearman on

As recently announced, the French and Luxembourg governments are finalising a new double tax treaty between the two countries (the «DTT»). We outline below the key revisions and their potential impact. 1. Withholding...more

Farrell Fritz, P.C.

When Investing In A Partnership May Be A Tax Problem

Farrell Fritz, P.C. on

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

Morrison & Foerster LLP

European M+A News, Winter 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

Skadden, Arps, Slate, Meagher & Flom LLP

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

McDermott Will & Emery

Focus on Tax Controversy - Summer 2015

McDermott Will & Emery on

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

Proskauer Rose LLP

UK Supreme Court case of Anson v. HMRC [2015] UKSC 44

Proskauer Rose LLP on

Delaware LLC held to be UK tax transparent - The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC as transparent for UK tax...more

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