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Dividends Tax Treaty

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

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On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

A&O Shearman

The new Luxembourg/United-Kingdom tax treaty has been signed.

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More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more

Goodwin

The UK and Luxembourg Signed A New Double Tax Treaty

Goodwin on

On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more

Barnea Jaffa Lande & Co.

Israeli-UAE Tax Treaty – Client Update

On May 31, 2021, Israel and the United Arab Emirates signed a tax treaty. This is the first tax treaty between the states. It is expected to go into effect on January 1, 2022, after passing the necessary ratification...more

Goodwin

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

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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

Amendments to Russian Tax Treaties

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In his address to the nation on 25 March 2020, the Russian President requested the government to implement measures ensuring the adequate taxation of Russian-sourced dividend and interest payments to "offshore" jurisdictions....more

Goodwin

New France-Luxembourg Double Taxation Treaty

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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

King & Spalding

The New France-Luxembourg Double Tax Treaty: First Comments Relating to Investment in French Real Estate

King & Spalding on

On 20 March 2018, the Governments of France and Luxembourg signed a new French- Luxembourg treaty (the “New Treaty”), which will have an impact for certain investments in French real estate. Several changes were...more

Bilzin Sumberg

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

Bilzin Sumberg on

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

Dechert LLP

Brexit – The UK and International Tax Consequences

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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

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

Bilzin Sumberg

Use of Estonia in U.S. International Tax Planning

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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

Troutman Pepper

Planning For Qualified Dividend Income When Taking Foreign Companies Public - Tax Update Volume 2015, Issue 2

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Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income...more

Bilzin Sumberg

IRS Denies Treaty Benefits Despite Lack of Treaty Shopping

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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

Bilzin Sumberg

Retroactive Tax Planning

Bilzin Sumberg on

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

Bilzin Sumberg

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

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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

Baker Donelson

2013 Amendments to United States and Japan Income Tax Treaty

Baker Donelson on

On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more

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