News & Analysis as of

Double Taxation

HMT Unveils Strategy for Future of UK's Asset Management Industry

by Dechert LLP on

HM Treasury recently published its Investment Management Strategy II Report. Building on its 2013 strategy report ? which mainly focused on how to improve the UK as a fund domicile ? this report sets out the UK government’s...more

Estate Planning Pitfall - You’re retiring to a foreign country

If plans call to relocate to another country after retirement, be aware that they may be tarnished if a person doesn’t look into all potential estate tax and income tax implications first. This brief article explores three...more

Insight on Estate Planning - Year End 2017

In This Issue: - When should you turn down an inheritance? - Addressing intellectual property requires careful estate planning - Year end is an ideal time to review your estate plan - Estate planning pitfall: You’re...more

Kyiv Tax Newsletter (Ukrainian) - November 2017 #2

by Dentons on

On 9 October 2017, the Government of Ukraine and the Government of the United Kingdom of Great Britain and Northern Ireland signed the Protocol for introduction of amendments into the Convention between the Government of...more

Kyiv Tax Newsletter - November 2017 #2

by Dentons on

Increased withholding tax rates in the instances of application of the Convention between the Government of Ukraine and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double...more

UK Tax Round Up - October 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more

European Union adopts new Directive to better resolve double taxation disputes

by DLA Piper on

The Council of the European Union adopted the Tax Dispute Resolution Mechanism Directive on 10 October 2017. Whereas currently the scope for mandatory arbitration in dispute resolution is limited to transfer pricing...more

Investor-Friendly Tax Treaty Set for Mexico and Spain

by Jones Day on

The Situation: A Tax Treaty developed to avoid double taxation, negotiated between Mexico and Spain in late 2015, was just recently published in the official gazettes of both nations. The new protocols are effective September...more

Swiss-Domiciled Company Denied Treaty Benefits For Treaty Shopping

by Fox Rothschild LLP on

Statutory Background- When a foreign corporation receives dividends from U.S. sources, the income is generally subject to tax at 30%. To avoid double taxation and encourage cross-border investments, the U.S. has entered...more

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

Protocol Amending the Mexico–Belgium Tax Treaty Published

by Jones Day on

On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion ("Tax Treaty") between Belgium and Mexico was published in Mexico's Official Journal...more

The Importance of Timely Electing Your Foreign Earned Income Exclusion

Life as an American living abroad can conjure idyllic notions of painting en plein air in Paris or negotiating a last minute deal in Brussels. Not so idyllic, however, is the reality of filing U.S. tax returns from overseas....more

IRS Provides Guidance on Stock Distributions for Publicly Offered REITs and RICs

by Latham & Watkins LLP on

Revenue procedure sets forth requirements for ensuring certain stock distributions are treated as property distributions eligible for dividends paid deduction. On August 11, 2017, the Internal Revenue Service (IRS)...more

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

The UK Double Tax Treaty Passport Scheme – Changes for the UK Loan Market

by Morrison & Foerster LLP on

The UK Double Tax Treaty Passport (“DTTP”) scheme has recently been extended by HM Revenue & Customs (“HMRC”) to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme. The aim of the amendments is...more

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Tax Round Up - May 2017

by Proskauer Rose LLP on

Budget and Finance Bill - General Election – Finance Bill (No.2) 2017 Curtailed - The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more

Development of court practice of determining direct capital investment for the purpose of applying the 5% withholding tax rate...

by Dentons on

On 3 May 2017 the Commercial Court of Chelyabinsk Region rendered a decision in case No. ?76-20508/2016 under the claim of Chelyabenergosbyt PJSC (the “Company”)....more

2017 budget impacts for innovation and technology

by DLA Piper on

From a Government which had promised much in the way of innovation, the 2017 Budget is both underwhelming and, in one respect, potentially concerning. In terms of 'in' words, 'infrastructure' is very much in; 'innovation'...more

Extensions to the double tax treaty passport scheme

by DLA Piper on

The double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under...more

Prepared for the Border Adjustment Tax? A U.S. and Global Perspective

by K&L Gates LLP on

K&L Gates' Global Tax Group has been monitoring the potential impact of the Border Adjustment Tax (BAT) across a number of jurisdictions. In our 14 February 2017 update, we commented that issues regarding the legality of...more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Equity Incentives Update - Spring 2017

by DLA Piper on

Welcome to issue 1 of our Equity Incentives Update, dedicated to keeping companies informed about legal and regulatory developments affecting share-based incentives. In this issue we cover... Please see full...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Tax Planning in Uncertain Times

by McNair Law Firm, P.A. on

There is a long list of reforms that the Trump administration intends to tackle and one of the items on the list is tax reform. Although there are multiple proposals by various players and significant variations among the...more

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