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International Tax Issues

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

Información tributaria de 36 países ya está en Colombia

by Holland & Knight LLP on

Por medio del comunicado de prensa No. 149 del 9 de octubre, la DIAN informó que en desarrollo de los Acuerdos de Intercambio de Información vigentes y de la Ley FATCA, recibió la información correspondiente al año 2016, de...more

M&A Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more

More Specifics Come Out in New Trump Tax Plan

by Barley Snyder on

The Trump administration on Wednesday released its “Unified Framework for Fixing Our Broken Tax Code.” The reforms outlined in the documents provide more specificity than prior White House plans, but a number of specifics...more

U.S. Tax Reform Effort Moves Forward

by Hogan Lovells on

On September 27, 2017, Republican leaders of the tax reform effort in the U.S. House of Representatives, the U.S. Senate, and the Trump Administration released a "Unified Framework for Fixing Our Broken Tax Code," providing...more

Trump Tax Reform Roadmap Released

by Butler Snow LLP on

On Wednesday President Trump and congressional Republicans unveiled their long-awaited framework for overhauling the United States tax code. Although much of the content was expected, the proposal is notable because it...more

Republican Leaders Release Tax Reform Framework

by McDermott Will & Emery on

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on tax reform. This outline will serve as a useful framework in structuring what will be an active, and...more

State and Local Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on federal tax reform. The states conform to the federal tax laws to varying degrees and the extent to...more

Tax Reform Update: Administration and Congressional Officials Unveil Framework

by Latham & Watkins LLP on

The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details. On September 27, a group of Trump Administration and Congressional leaders...more

Out of Compliance Taxpayers: Beware of new IRS-Programs!

by Foodman CPAs & Advisors on

The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS. Its conviction rate of over 90% is one of the highest in federal law enforcement. Those convicted pay taxes, penalties and...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

by McDermott Will & Emery on

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...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

Avoiding HR Pitfalls While Managing Overseas Assignments: Your 10-Point Checklist

More businesses than ever are sending people overseas. The rewards of developing new markets can be great, but the multitude of different legal systems mean there are also bear traps to be avoided—especially on the human...more

Cumplimiento Fiscal Internacional

by Foodman CPAs & Advisors on

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Can Foreign Partners Now Exit Partnerships Tax Free?

by Bracewell LLP on

In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more

Grecian Magnesite: Tax Court Finds Reliance on a US Tax Advisor Establishes Reasonable Cause

On July 13, 2017, the Tax Court, in Grecian Magnesite, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. 3 (2017), rejected Internal Revenue Service (IRS) arguments that, in order to establish good faith reliance, the...more

Impact of the Multilateral Instrument on U.S. Taxpayers

by Alston & Bird on

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all...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

Tax Law Changes in Saudi Arabia

by Jones Day on

On June 11, 2017, the Saudi Arabian Excise Tax Law ("Excise Tax Law"), as enacted by Royal Decree No. M/86 and dated 27/8/1438 H / May 23, 2017, came into force in Saudi Arabia. The new law implements the GCC Unified...more

Italy Addresses "Carried Interest" Tax Treatment

by Jones Day on

The Italian government has enacted Law Decree no. 50 ("Decree 50"), providing a set of new tax measures aimed at, among other things, attracting investments in Italy. Decree 50 was finally approved by the Italian Parliament...more

ICAP: It's Not a TRAP

by Alston & Bird on

An IRS official recently stated that the United States will participate this fall along with several other countries in a pilot of the “international compliance assurance program (ICAP). ICAP is a “tax risk assessment...more

BEPS Update: OECD Multilateral Instrument Signed

by Proskauer - Tax Talks on

On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS),...more

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

Tax administrations prepare for automatic exchange of CbC reports - are you ready? Three takeaways

by DLA Piper on

OECD announced that another important step has been taken to implement country-by-country (CbC) reporting requirements, as signatories to the Multilateral Competent Authority Agreement on the Exchange of CbC Reports (the CbC...more

Implications of the Chevron Case for Multinational Clients

by K&L Gates LLP on

In recent years, the Australian Taxation Office (ATO) has focused much energy in the transfer pricing arena, firstly due to the issue becoming part of the OECD's ongoing investigation into international tax practices and...more

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