News & Analysis as of

Foreign Tax

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

by Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

Inbound and Outbound U.S. Tax Planning - What's Left After the MLI?

by Bilzin Sumberg on

On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place. ...more

Blog: Failure to Prevent Criminal Facilitation of Tax Evasion

by Cooley LLP on

The new UK “failure to prevent criminal facilitation of tax evasion” domestic and overseas offences will almost certainly become effective in or before September 2017. What does this mean for companies and firms? The offences...more

A Guide to UK Tax on Commercial Real Estate: Non-Residents

by King & Spalding on

1. Introduction - This client alert provides a summary of key UK tax considerations when a nonresident invests into UK commercial real estate. There are a number of holding structures for investment into UK real estate...more

MoFo Tax Talk: Volume 9, Issue 4

by Morrison & Foerster LLP on

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

"The New UK Corporate Offence of 'Failure to Prevent the Facilitation of Tax Evasion': Implications for Fund Managers and...

The U.K. government expands its crackdown on tax evaders and the persons who assist them, by targeting businesses who fail to prevent tax evasion....more

BEPS: OECD Releases Multilateral Tax Treaty Convention

by Proskauer - Tax Talks on

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more

The Panama Effect: UK Government accelerates proposals to criminalise failure to prevent tax evasion

by Latham & Watkins LLP on

10 considerations for professionals and corporates worldwide in advance of the new law. Overview - In a move widely seen as a response to the so-called “Panama Papers” revelations, the UK Government has enhanced...more

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

by Goulston & Storrs PC on

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs. ...more

Could 2016 Be the Year When Congress Finally Addresses Tax Reform?

by King & Spalding on

Like Vladimir and Estragon waiting for Godot, Washington has been waiting for Congress to tackle tax reform. The reason for the lack of action is a fundamental disagreement between Democrats and Republicans over what reform...more

IRS Publishes Guidance for RICs that Receive Foreign Tax Credit Refunds

by Morgan Lewis on

IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more

Federal Circuit Narrowly Interprets Limitations Period for Foreign Tax Credit Refund Claims

by McDermott Will & Emery on

In Albemarle Corp. v. United States, No. 2015-5015 (Fed. Cir. Aug. 13, 2015), the United States Court of Appeals for the Federal Circuit disallowed claims for refund related to foreign taxes paid by Albemarle Corporation...more

Who Bears Withholding Tax When a Settlement of Litigation Agreement Is Silent?

by Pepper Hamilton LLP on

IF A SETTLEMENT AGREEMENT IS SILENT, A DEFENDANT IS NOT REQUIRED TO ‘GROSS UP’ THE SETTLEMENT, AND THE PLAINTIFF WILL SUFFER THE WITHHOLDING TAX BURDEN. What happens when settling parties agree that the defendant will...more

Focus on Tax Controversy and Litigation - Supreme Court Decides Maryland v. Wynne and Rules that Maryland Tax Scheme Is...

by Shearman & Sterling LLP on

In This Issue: - Maryland’s Tax Scheme Ruled Unconstitutional - “FTC Generator” Case Update - FSA Rules that Equitable Disgorgement May be Deductible Expense - District Court Upholds Attorney Client...more

Tax Policy Update

by McGuireWoods LLP on

NUMBER OF THE WEEK: 52 percent. The likelihood that tax reform will happen in 2017 or earlier, according to the tax experts that participated in the Tax Council (TTC) and Ernst & Young (EY) Tax Reform Business Barometer in...more

CFPB Subjects Large International Money Transmitters to Supervision

by Davis Wright Tremaine LLP on

The Consumer Financial Protection Bureau (CFPB) finalized its rulemaking defining larger participants in the international money transfer market. Companies that engage in at least one million international money transfers...more

Tax Planning for the Privatization of the Space Industry

by Bilzin Sumberg on

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

The Shadow Transfer Pricing Rules: Crediting Foreign Taxes

by K&L Gates LLP on

At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more

Credit for Foreign Taxes Paid Not Available Against New 3.8% Net Investment Income Tax

by Hodgson Russ LLP on

Previously, many U.S. citizens living abroad eliminated their U.S. income tax liabilities with a credit for foreign taxes paid; however, individuals who are subject to the new 3.8 percent net investment income tax (NIIT) may...more

CFPB updates remittance rule small business guide and makes “clarificatory” amendment and technical correction to rule

by Ballard Spahr LLP on

The CFPB has updated its small business guide on the remittance transfer rule to reflect the changes to the rule that were made this past May dealing with the scope of the error resolution procedures, disclosure of recipient...more

OECD releases “BEPS” Action Plan – a sweeping international tax effort to combat base erosion and profit shifting

by DLA Piper on

The OECD’s Committee on Fiscal Affairs (CFA) has published its Action Plan to address Base Erosion and Profit Shifting (BEPS). This sweeping international effort aims to combat a comprehensive range of international tax...more

Native Title Taxation Measures Pass In Final Sitting Week (Australia)

by DLA Piper on

SUMMARY - In its final sitting week, the Commonwealth Parliament passed three pieces of legislation which include important measures aimed at clarifying the taxation treatment of payments and benefits provided under...more

German Federal Tax Court: Distributions from U.S. Trusts Are Subject to German Gift Tax

by McDermott Will & Emery on

The German Federal Tax Court clarified that distributions from foreign trusts to beneficiaries resident in Germany are subject to German gift taxation, but did not address the possible imposition of both gift and income tax...more

CFPB Proposes Revisions to Rules on International Money Transfers by Consumers

by Foley & Lardner LLP on

The Consumer Financial Protection Bureau (CFPB) recently issued proposed changes to the rule it originally proposed on January 20, 2011, governing certain electronic money transfers by consumers that was required by the...more

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