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Multinationals

Tax Act: Significant International Provisions

by WilmerHale on

Prior to the Tax Act, the principal method for avoiding the double taxation of overseas corporate earnings—once by the local country and a second time by the United States as the multinational's home country—was the foreign...more

Kyiv Tax Newsletter (Ukrainian) #2

by Dentons on

On 27 December 2017, the Cabinet of Ministers of Ukraine approved, by its Order No. 1045, the List of states (territories), which comply with the criteria set in paragraph 2) of subsection 39.2.1 (Section 39.2 of Article 39...more

Kyiv Tax Newsletter - January 2018 #2

by Dentons on

The Cabinet of Ministers revised the list of low-tax jurisdictions for the purposes of transfer pricing - On 27 December 2017, the Cabinet of Ministers of Ukraine approved, by its Order No. 1045, the List of states...more

US Tax Reform Measures Affecting Foreign Multinationals

by McDermott Will & Emery on

On December 22, 2017, President Trump signed broad tax reform legislation into law that, among other things, reduced the corporate income tax rate to 21 percent and reformed the US international tax system. This article...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

by Latham & Watkins LLP on

Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more

Changes Abound in New Tax Bill for Multinational Companies

by Williams Mullen on

Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the “Act”), deal with the taxation of multinational companies. The taxation of foreign earnings has long been a point of contention...more

The E-Commerce Trend Continues in High Gear: How are Ocean/Air and Other Transportation Intermediaries Responding?

by Husch Blackwell LLP on

We think it is relevant, even at this early stage at the commencement of 2018, so close to the 2017 holiday season, to note that the e-commerce explosion will continue in full force and will in the natural course of events...more

Foreign Investment Control Heats Up: A Global Survey of Existing Regimes and Potential Significant Changes on the Horizon

by Jones Day on

Mergers and acquisitions by multinational companies require attention to foreign investment controls around the world, and such controls vary widely. For example, requirements for determining whether such controls apply, the...more

Enhancing social protection of international employees assigned to Belgium

by DLA Piper on

Each employer who wants to occupy foreign workers (or self-employed for that matter) in Belgium must (unless those excluded by law) preliminarily declare their employment to the Belgian labour authorities via a so-called...more

Australian Government releases hybrid mismatch rules to counteract entities exploiting differences in the taxation treatment of an...

by DLA Piper on

Introduction and overview - The Australian Treasurer, the Hon Scott Morrison MP, on Friday 24 November, released exposure draft legislation to prevent entities that are liable to Australian income tax from avoiding income...more

Forum non-conveniens and access to remedy in transnational business and human rights litigation: an update from Brexit Britain and...

by Hogan Lovells on

What is forum non-conveniens? According to the principle of “forum non-conveniens” (or inconvenient forum), a court has the power to dismiss a civil action where an appropriate and more convenient alternative forum exists. ...more

State Aid in Disguise?—EC Investigates UK Tax Regime

by Jones Day on

The Background: The European Commission has opened an in-depth investigation into a specific provision of the UK-controlled foreign company rules. The Issue: The Commission will investigate whether the UK's so-called Group...more

What Multinational Companies in Argentina Need to Know About Anti-Corruption Now

by Kobre & Kim on

Underscored by the recent contentious presidential and congressional elections, during which corruption was — as it is throughout the region — a hot-button issue, anti-corruption enforcement in Argentina is on the rise....more

Multinational Company in China – Are You Concerned About the Personal Credit System and Privacy Provisions in China? You Should...

by Seyfarth Shaw LLP on

Seyfarth Synopsis: The People’s Republic of China is making progress in implementing its mandatory “social credit system.” Multinational businesses in China should be watchful of this system, and ready for it when it rolls...more

How Well Do Your Anti-Harassment Tools Work Overseas?

by Littler on

The 2017 tsunami of high-profile sex harassment allegations against politicians, entertainers and news reporters has employers rethinking their approach to eradicating workplace harassment. And this issue is global—the news...more

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

Deemed Dividends Under Proposed Tax Reform

by Miles & Stockbridge P.C. on

2017 tax reform efforts may alleviate adverse deemed dividend tax treatment of foreign subsidiary support for the obligations of U.S. parent companies. Present support is limited to the pledge of 66 ?rds of the stock in...more

Congressional Tax Reform Proposals: Businesses Will Need to Rethink Key Decisions

by Latham & Watkins LLP on

Potential legislation would significantly affect businesses across a variety of sectors. Key Points: ..US House and Senate have each passed comprehensive tax reform legislation. ..Proposals would alter fundamental...more

Tax Residency - Place of Effective Management in South Africa

by Dentons on

The concept of residency is a crucial determinant in establishing a person’s tax obligations in South Africa. Generally, a resident is liable to pay tax on taxable income derived from South Africa and globally, while...more

Australian Tax Update

by DLA Piper on

Introduction and overview The Australian Treasurer, The Hon Scott Morrison MP, on Friday 24 November 2017, released exposure draft legislation to prevent entities that are liable to Australian income tax from avoiding...more

EU Opens Investigation Into UK Tax Scheme for Multinationals

by Bryan Cave on

The EU State aid rules are designed to stop Governments and local authorities giving companies a selective advantage, as doing so would create an unequal playing field. Say for example, a competitor in one country was given a...more

China's State Secret Laws: What To Do When Trade Secrets Collide with State Secrets

by Kobre & Kim on

Multinational companies doing business in China should treat the sensitive information received from their Chinese partners with special care, particularly if the information originates from a state-owned enterprise (SOE)....more

USCIS Establishes New Five-Prong Test for “Function Managers”

Multinational companies that wish to transfer managerial employees to the United States now have clarification on the criteria required to do so. A new five-prong test adopted by U.S. Citizenship and Immigration Services...more

Worldwide Territoriality: International Tax Proposals Broaden the Base

On November 16, 2017, the House of Representatives passed a much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (the House Plan), which was first introduced on November 2, 2017. The passage of the House Plan...more

Technology companies and transfer pricing

by Hogan Lovells on

What is transfer pricing? In basic terms, transfer pricing is the process by which multinational enterprises go about determining what jurisdictions their global profits are booked in. It’s something they have to do in...more

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