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International Tax Issues

Dorsey & Whitney LLP

Cross-Border de-SPAC Structures

Dorsey & Whitney LLP on

More special purpose acquisition vehicles (common known as “SPACs”) completed their initial public offering (“IPO”) in 2021 than in any prior year. In 2021, approximately 613 SPACs completed their IPO within the United States...more

Stikeman Elliott LLP

GST/HST Input Tax Credit Claims: Does the Supporting Documentation Need to be Issued by the Supplier?

Stikeman Elliott LLP on

On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more

Dentons

Polish Deal 2.0: modifications of PIT and social and health insurance contributions

Dentons on

An amended version of the Polish Deal will come into effect on 1 July. Its main objective is to simplify settlements and replace regulations that have caused various interpretation doubts in practice with new solutions....more

Vinson & Elkins LLP

The UK Qualifying Asset Holding Company Regime – New HMRC Guidance Clarifies Application of Activity Condition to Credit Funds

Vinson & Elkins LLP on

HMRC has recently updated its guidance on the UK’s new qualifying asset holding company (QAHC) tax regime, which was introduced from 1 April 2022, to include examples of the application of the QAHC regime “activity condition”...more

Cadwalader, Wickersham & Taft LLP

European Commission Consultation on EU-wide Withholding Tax System

The European Commission has launched a public consultation on its proposal to introduce a new common EU-wide system for withholding tax on dividend or interest payments. The consultation period will end on 26 June 2022....more

Hogan Lovells

Zniesienie Stanu Epidemii – Skutki Dla Podmiotów Gospodarczych

Hogan Lovells on

Stan epidemii w związku z COVID-19 wprowadzono w Polsce 20 marca 2020 roku. Z dniem 16 maja 2022 roku, stan epidemii w Polsce został zniesiony i zastąpiony stanem zagrożenia epidemicznego. Podstawą prawną dla tej zmiany było...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

Hogan Lovells

Lifting the state of epidemic - effects on economic entities

Hogan Lovells on

The state of epidemic for COVID-19 was introduced in Poland on 20 March 2020. As of 16 May 2022, the state of epidemic in Poland was lifted and replaced by the state of epidemic emergency. The legal basis for this change was...more

Dentons

New tax regulations applying to the mining sector

Dentons on

The National Executive Branch has recently passed Decree No. 308/22 and the General Resolution No. 5205/22. These regulations apply to the export duties and the fiscal stability benefit policy applying to the mining sector....more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 14, 2022

Kustoff Joins Ways and Means. Rep. David Kustoff (R-TN) has been selected to replace former Rep. Tom Reed (R-NY), who resigned from Congress earlier this year, on the House Ways and Means Committee. He will sit on the Worker...more

Dentons

UK/Luxembourg tax treaty signed

Dentons on

Overview - The UK and Luxembourg signed a new double tax treaty on 7 June 2022, which will eventually replace the existing treaty between the countries. The new treaty has significant implications for UK real estate...more

Proskauer - Tax Talks

HMRC Clarifies Application of QAHC Regime to Corporate Lending Vehicles

Proskauer - Tax Talks on

HMRC has recently updated the guidance relating to the UK’s new qualifying asset holding company (QAHC) tax regime which was introduced from 1 April 2022. The new guidance clarifies HMRC’s approach to whether corporate...more

Hogan Lovells

New Import Duty and Export Duty Law

Hogan Lovells on

The new Import Duty and Export Duty Law has been published in Mexico’s Federal Official Gazette. The publication took place on June 7, 2022. On June 7, 2022 the Ministry of Economy of Mexico published in the Mexican Official...more

Hogan Lovells

Nueva Ley de los Impuestos Generales de Importación y de Exportación

Hogan Lovells on

Se publica en el Diario Oficial de la Federación la nueva Ley de los Impuestos Generales de Importación y de Exportación. El 7 de junio de 2022 se publicó en el Diario Oficial de la Federación (DOF) la nueva Ley de los...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

Proskauer Rose LLP on

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Dentons

Dutch District Court rules on application of real estate investment company regime

Dentons on

On April 26, 2022, the North Holland District Court ruled that four Dutch real estate investment companies correctly claimed the Dutch fiscal investment institution regime (fiscale beleggingsinstelling, or FBI), which is a...more

International Wealth Tax Advisors

US DOJ Asks Supreme Court to Weigh In on FBAR Maximum Penalty Dispute

A debate over penalties for non-willful failure to disclose all of an individual’s or business’ foreigh bank accounts may reach the Supreme Court, if a Department of Justice request is granted, according to its recently filed...more

Dentons

Regulatory Tax Update: Crypto Assets

Dentons on

One impact of advances in information technology has been the digitalization of the economy. This kind of advance plays a crucial role in national economic growth. Various forms of economic digitalization have resulted in the...more

Cadwalader, Wickersham & Taft LLP

A Step Forward for a Corporate Re-domiciliation Regime for the UK

On 12 April 2022, the UK Government published a summary of responses to the consultation on a corporate re-domiciliation regime. We have previously covered the proposed consultation when it was announced as part of the UK...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, May 24, 2022

Tax Staffers Discuss State of Tax Policy. At a tax conference last week, top officials from the Biden administration and key congressional staffers discussed the latest in tax policy. One panel, which was focused on the...more

Proskauer - Tax Talks

EU Commission publishes draft directive to remove tax driven debt-equity bias

Proskauer - Tax Talks on

Summary and Background - On 11 May 2022, the European Commission (the “Commission”) published its draft proposal for a debt-equity bias reduction allowance (“DEBRA” or, the “Directive”), which forms part of the...more

Dentons

Dutch District Court: Interposition of an EU company is abuse of EU law

Dentons on

On May 4, 2022, the Dutch Zeeland-West Brabant District Court ruled that the interposition of a Luxembourg holding company by a non-EU private equity fund to own a 15.3 percent interest in a Dutch company constituted abuse of...more

Miller Nash LLP

Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates

Miller Nash LLP on

Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the...more

International Wealth Tax Advisors

Tax Transparency in Latin America and the Engel List

Part two of a two-part series on the Engel List - Illicit financial flows and corruption are a major concern across Latin America, as governments in the Americas try to stop billions of dollars from leaving the region...more

International Wealth Tax Advisors

TIGTA Highlights the IRS’ FATCA Enforcement Woes

In the first 12 years of the U.S. Foreign Account Tax Compliance Act, the IRS has spent nearly $600 million on enforcement but has only managed to collect $14 million in penalties in return. This poor performance indicates...more

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Updated: Dec 28, 2021:

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Information for EU and Swiss Residents

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Privacy Officer
JD Supra, LLC
150 Harbor Drive, #2760
Sausalito, CA 94965

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Privacy Officer
JD Supra, LLC
150 Harbor Drive, #2760
Sausalito, CA 94965

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Contacting JD Supra

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Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

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