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Organization for Economic Co-operation and Development Income Taxes

Walkers

Bermuda Corporate Income Tax Considerations for Captive Insurers

Walkers on

The operating provisions of the corporate income tax regime for Bermuda legislation will be effective for fiscal years beginning on or after 1 January 2025. This will apply to "Bermuda Constituent Entities" of an "In Scope...more

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

Walkers

Guernsey announces further details of OECD Pillar Two implementation

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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

Proskauer Rose LLP

UK Tax Round Up - April 2024

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Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Proskauer Rose LLP

UK Tax Round Up - January 2024

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Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Conyers

Government of Bermuda Consulting on Possible Introduction of Corporate Income Tax

Conyers on

In response to the Pillar Two global minimum tax rules (the GloBE Rules) set out by the Organisation for Economic Co-operation and Development (OECD), the Government of Bermuda has issued a public consultation paper...more

Proskauer Rose LLP

UK Tax Round Up - July 2023

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Welcome to July’s edition of our UK Tax Round Up. This month has seen a number of interesting tribunal decisions, including the denial of double tax relief and of employee expense deductions and the taxation on loans to a...more

Proskauer Rose LLP

UK Tax Round Up - March 2023 - 2

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Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

Cadwalader, Wickersham & Taft LLP

EU List of Non-Cooperative Jurisdictions Expanded

On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more

Proskauer Rose LLP

UK Tax Round Up - November 2022

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Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more

Goodwin

Luxembourg Draft Budget Law 2023: The Most Awaited Reverse Hybrid Clarification

Goodwin on

​​​​​​​On 12 October 2022, the finance minister presented the Luxembourg budget bill for fiscal year 2023. For corporate tax payers, and particularly for funds, there is a most welcomed clarification on the scope of the...more

Freeman Law

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

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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

Freeman Law

Country-by-Country Reporting

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In recent years, tax authorities across the globe have adopted a number of OECD-led initiatives aimed at curbing the ability of multinational enterprises to engage in so-called Base Erosion and Profit Shifting (BEPS) (i.e.,...more

Miller Nash LLP

Today in Tax: U.S. Tax Treaty Updates—Chile, Croatia, and Hungary

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD)...more

Proskauer Rose LLP

UK Tax Round Up - July 2022

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Welcome to July’s edition of the UK Tax Round Up. This month has seen an interesting decision of the First-tier Tribunal on the salaried member rules as they apply to asset manager LLPs, a surprising decision on the terms...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

Davies Ward Phillips & Vineberg LLP

Canada Confirms Intention to Institute New Interest and Deductibility Rules

The Department of Finance (Canada) (Finance) released draft legislation on February 4, 2022 that would limit the deduction of “interest and financing expenses” to a fixed percentage of earnings before interest, taxes,...more

Snell & Wilmer

Taxation of Cryptocurrency and Similar Transactions

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Whether you’re an investor expanding your portfolio to include digital assets such as cryptocurrencies and tokens, a business that uses cryptocurrencies to engage in everyday transactions, or a crypto “miner," you need to...more

Proskauer Rose LLP

UK Tax Round Up - March 2022

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Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more

Foodman CPAs & Advisors

Cómo las Administraciones Tributarias Manejan el Incumplimiento de FATCA, CRS

Las administraciones tributarias pueden utilizar una combinación de medidas de detección, preventivas y correctivas para evaluar y tratar Ley de Cumplimiento Tributario de Cuentas Extranjeras (FATCA) y el incumplimiento del...more

Miller Nash LLP

Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies

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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more

Freeman Law

OECD Issues Model Rules on Nexus and Sourcing

Freeman Law on

On February 4, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued model rules for nexus and revenue sourcing under Pillar One of the international tax agreement (the so-called “two-pillar...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, February 8, 2022

Legislative Lowdown - Build Back Better Reboot. Rep. Richard Neal (D-MA), the House Ways and Means Committee chair, and Sen. Ron Wyden (D-OR), chair of Senate Finance Committee, are cautiously optimistic negotiations over...more

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