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Mergers International Tax Issues

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more

Arnall Golden Gregory LLP

AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders

In this episode, Mike Burke, AGG Corporate partner and leader of the Ireland & Northern Ireland practice, explores U.S. tax considerations for foreign businesses scaling to the U.S., including issues such as the branch...more

Holland & Knight LLP

DIAN Colombia: No compensación de pérdidas en integración de sucursales de sociedad extranjera

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En Oficio #1356 del 9 de noviembre de 2022, la Dirección de Impuestos y Aduanas Nacionales (DIAN) señaló que la integración en Colombia de dos sucursales de sociedades extranjeras, como resultado de una fusión entre sus dos...more

K&L Gates LLP

Doing Business in the United States

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Companies operating in the United States encounter numerous legal and regulatory issues arising from doing business in the world’s largest economy. Anticipating and dealing appropriately with those issues can improve markedly...more

White & Case LLP

Spain to tax acquisitions of shares of major Spanish listed companies

White & Case LLP on

The Spanish Official Gazette published last October 16th legislation enacting a new indirect Tax on Financial Transactions levied, at 0.2%, on the acquisition of shares of major Spanish listed companies irrespective of the...more

Jones Day

China Further Opens its Market with New "Foreign Investment Law"

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The Situation: The new PRC Foreign Investment Law ("FIL"), as well as its Implementing Regulations ("Implementing Regulations"), took effect on January 1, 2020. In addition to the FIL and the Implementing Regulations, the...more

Jones Day

Australian Taxation Office Increases Scrutiny of Australian Inbound Investments

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The Situation: The Australian Taxation Office ("ATO") has broadened its role in the process for reviewing foreign investment proposals, through closer engagement with foreign investors pursuing acquisitions, mergers and...more

Faegre Drinker Biddle & Reath LLP

Leveraged Acquisitions Roundtable

Drinker Biddle’s Corporate and Securities Group recently hosted its 13th annual roundtable discussion, which took place at Gulph Mills Golf Club in King of Prussia, Pennsylvania. This year’s event sported a new name—“The...more

A&O Shearman

Section 385 Treasury Regulations Developments

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Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected - On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more

Proskauer Rose LLP

UK Tax Round Up - September 2019

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Case Law Developments - Place of supply for VAT purposes - The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more

Proskauer Rose LLP

UK Tax Round Up - August 2019

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UK Case Law Developments - Valid notice crucial to tax indemnity claim - The Court of Appeal (CA) decision in Stobart Group Ltd v Stobart and another is a cautionary tale for any purchaser who, following the...more

Womble Bond Dickinson

Foreign Direct Investment in the US – Guidance for the European Investor

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On July 2, 2019, the Bureau of Economic Analysis released the 2018 numbers for foreign direct investment (FDI) in the US. Total 2018 FDI was $273 billion and of that figure, European investors accounted for $116 billion or...more

Latham & Watkins LLP

Planning for Tax Controversies Before, During and After the Deal: New Dynamics in Cross-Border M&A Under the TCJA

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Considerable thought and commentary has been given to the numerous technical features introduced by P.L. 115-97 (Dec. 22, 2017), colloquially referred to as the “Tax Cuts and Jobs Act” (the “TCJA”). Nearly one-and-a half...more

Proskauer - Tax Talks

Upper Tribunal Rules in Favour of Taxpayer in Tax Residence Case

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Development Securities plc and others v HMRC [2019] UKUT 169 (TCC) - The Original Judgment - As we reported in our August 2017 UK Tax Round-Up [https://www.proskauer.com/newsletter/uk-tax-round-up-august-2017], the...more

Proskauer Rose LLP

UK Tax Round Up - April 2019

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UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more

Proskauer Rose LLP

UK Tax Round Up - October 2018

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General UK Tax Developments - CIOT responds to the draft profit fragmentation provisions in the Finance Bill 2019 - The Chartered Institute of Taxation (CIOT) has published its response to the profit fragmentation...more

Bennett Jones LLP

Due North: U.S. Private Equity Sets Sights On Canada - Infographic

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The outlook for private equity investment in Canada is promising. The country has become an attractive destination for foreign investors, and the total value of PE deals continues to reach new heights. A strong Canadian...more

Bennett Jones LLP

Due North: U.S. Private Equity Sets Sights on Canada

Bennett Jones LLP on

The outlook for private equity investment in Canada is promising. The country has become an attractive destination for foreign investors, and the total value of PE deals continues to reach new heights. A strong Canadian...more

Latham & Watkins LLP

Tax Reforms Fuel US M&A Activity

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The fundamental US tax reforms brought in this year by the Tax Cuts and Jobs Act (TCJA) have changed the tax landscape for M&A more significantly than any other legislation in the modern era. Businesses and tax advisors will...more

Proskauer Rose LLP

UK Tax Round Up - May 2018

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General UK Tax Developments - Enterprise management incentive (EMI) options State Aid approval - We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more

A&O Shearman

What Role For Fairness in EU Competition Policy and Enforcement?

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Is this perception well-founded? And does it represent a new policy trend towards ‘social justice’ objectives or simply a continuation of a policy driver that has underpinned EU competition enforcement for some time?...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part IX: Impact on M&A Transactions

Foster Garvey PC on

The Tax Cuts and Jobs Act (“TCJA”) will significantly impact merger and acquisition (“M&A”) activity. Although billed as tax reform, the TCJA did not reform or simplify the Internal Revenue Code (“Code”). Virtually none of...more

Proskauer - Tax Talks

Impact of Recent Tax Legislation on M&A Transactions

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This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...more

Sheppard Mullin Richter & Hampton LLP

2018 EU Trade, Regulatory and Competition Trends

Our “trends for 2018” are only a selection of interesting developments to watch for in 2018. Within the political and legislative cycle of the European Union, 2018 promises to be an eventful year, given that it is the last...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

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