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Income Taxes › Corporate Taxes › International Tax Issues

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
International Lawyers Network

Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile

International Lawyers Network on

Maximiliano Concha Rodríguez is counsel with PAGBAM | Schwencke, Chile, the ILN's member firm. In this episode, Lindsay and Max chat about the unending tax reforms in Chile, the recent tax treaty between the US and Chile, and...more

Walkers

Guernsey announces further details of OECD Pillar Two implementation

Walkers on

Following on from the Crown Dependencies re-affirming their commitment to implementing the Organisation for Economic Co-operation and Development’s Pillar Two framework for accounting periods commencing on or after 1 January...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials

Skadden, Arps, Slate, Meagher & Flom LLP on

Tax of counsel Fred Goldberg and senior advisor for tax resolution strategies De Lon Harris, both formerly of the IRS, joined the hosts of “GILTI Conscience” for a comprehensive look at current developments at the agency,...more

Eversheds Sutherland (US) LLP

Chilean tax treaty enters into force

Eversheds Sutherland (US) LLP on

On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint

Skadden, Arps, Slate, Meagher & Flom LLP on

Our latest “GILTI Conscience” podcast featured Deloitte international tax partner Sam Gordon, who joined hosts Nate Carden and David Farhat for an in-depth look at Asia Pacific’s perspective on Pillar Two, particularly from...more

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

Allen Barron, Inc. on

Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

BCLP

What You Need to Know About the Amendments to VAT in Para-Hotel Business

BCLP on

The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more

Blake, Cassels & Graydon LLP

Propositions législatives du 4 août 2023 : Présentation de certaines mesures fiscales

Blake, Cassels & Graydon LLP on

Le 4 août 2023, le ministère des Finances (le « ministère ») a publié de multiples propositions législatives et notes explicatives connexes (les « propositions du 4 août »). Ces propositions du 4 août comprennent des...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good

Skadden, Arps, Slate, Meagher & Flom LLP on

In our third installment of the “GILTI Conscience” pro bono spotlight series, counsel Jared Binstock and associate Sanessa Griffiths joined the podcast hosts to discuss how they’ve utilized their corporate tax backgrounds to...more

Cadwalader, Wickersham & Taft LLP

Pin-pointing Residence

Cadwalader, Wickersham & Taft LLP on

The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

Blake, Cassels & Graydon LLP

2023 August 4 Draft Legislation: Selected Tax Measures

Blake, Cassels & Graydon LLP on

On August 4, 2023, the Department of Finance (Finance) released a significant package of draft legislative proposals and related explanatory notes (August 4 Proposals). The August 4 Proposals include updated legislative...more

A&O Shearman

Luxembourg tax administration issues guidance on the tax treatment and reporting obligations of reverse hybrid entities

A&O Shearman on

On 9 June 2023, the Luxembourg tax administration (the LTA) issued circular L.I.R. n°168quater/1 (the Circular) providing long-awaited guidance on the application of article 168quater of the Luxembourg Income Tax Law (the...more

Hogan Lovells

Dividend income is excluded from the EBITDA for the purpose of the Spanish interest limitation rule

Hogan Lovells on

The Spanish interest limitation rule establishes that net financial expenses are deductible for Spanish Corporate Income Tax ("CIT”) purposes with the annual limit of the higher of (i) 30% of the Tax EBITDA (as defined in the...more

Brownstein Hyatt Farber Schreck

Ways and Means Committee Republicans Release Pillar Two Remedies Proposal

Brownstein Hyatt Farber Schreck on

House Ways and Means Committee Chairman Jason Smith (R-MO) and committee Republicans released legislation on May 25, 2023, in response to the Pillar Two global minimum tax negotiated by the Organisation for Economic...more

Skadden, Arps, Slate, Meagher & Flom LLP

The 2024 Green Book and Tax Implications: A Primer

Skadden, Arps, Slate, Meagher & Flom LLP on

On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more

Hogan Lovells

Mexico | Taxation and Collection Master Plan for 2023

Hogan Lovells on

The Tax Administration Service published the coordination strategy for taxpayer audits for the fiscal year 2023, which mainly consists of management by the tax authority for taxpayer compliance, actions for the auditing of...more

Hogan Lovells

México | Plan Maestro de Fiscalización y Recaudación para 2023

Hogan Lovells on

El Plan Maestro de Fiscalización y Recaudación para el ejercicio de 2023 publicado por el Servicio de Administración Tributaria publicó la estrategia de coordinación para la fiscalización de contribuyentes, la cual...more

Hogan Lovells

UK: HMRC changes to notification process for opting to tax on land and buildings

Hogan Lovells on

Whilst the default position is that supplies of land and buildings are usually exempt from VAT (the sale of new commercial buildings excepted), landowners of commercial property will often choose to opt to tax their property...more

Freeman Law

Reviewing a Foreign Legal Structure

Freeman Law on

Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Hogan Lovells

Spain releases its long awaited draft list of non-cooperative jurisdictions

Hogan Lovells on

On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more

Freeman Law

Tax Residency Status Modification: Mexican Tax Implication

Freeman Law on

For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more

Akin Gump Strauss Hauer & Feld LLP

UK Mini-Budget - Helpful for Asset Managers

Akin Gump Strauss Hauer & Feld LLP on

The government’s 2022 Growth Plan, deceptively referred to as the “mini-budget,” has brought in notable changes likely to impact the funds industry. In particular, a number of the changes will help ensure the continued...more

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Orrick, Herrington & Sutcliffe LLP

UK Growth Plan ('Mini-Budget') 2022

Orrick, Herrington & Sutcliffe LLP on

On 23 September 2022, the UK Government announced a number of significant tax changes in its Growth Plan (widely referred to in the media as a ‘Mini-Budget’). Here are ten key takeaways, of particular relevance to our...more

Freeman Law

International Tax Concepts: Dual-Status Taxpayers

Freeman Law on

A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more

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