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
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
On February 5, 2024, the French Supreme Tax Court (Conseil d’État) voided French tax authority guidelines from May 2023 that provided that shares acquired upon the exercise of founder stock options, or Bons de Souscription de...more
EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE -
On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more
6/6/2022
/ American Bar Association (ABA) ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Taxes ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
EU ,
European Commission ,
GILTI tax ,
Investigations ,
Member State ,
Model Rules ,
OECD ,
Pillar 2 ,
Sustainability ,
Tax Rates ,
White Collar Crimes
INTRODUCTION TO US TAXATION OF NFTS -
Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more
5/5/2022
/ Asset Management ,
Buyers ,
Charitable Donations ,
Corporate Taxes ,
Cross-Border ,
Donations ,
EU ,
Foreign Tax Credits ,
Germany ,
GILTI tax ,
Global Market ,
Income Taxes ,
International Tax Issues ,
Investment ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Pay-for-Performance ,
Remote Working ,
Sellers ,
Trustees ,
U.S. Treasury ,
UK ,
Withholding Tax
The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more
WHAT IS THE AIM OF PILLAR 2 RULES?
The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework’s project is to ensure that multinational groups of companies pay a minimum level of tax...more
In a landmark decision of 11 December 2020 involving digital player Conversant (fka Valueclick), the French Supreme Tax Court (Conseil d’État) ruled that a French company can qualify as a dependent agent, and thus as a French...more
The French Supreme Tax Court (Conseil d’État) ruled that the French withholding tax on the capital gain derived from the disposal of a substantial shareholding in a French company by a non-resident company is not compliant...more
The Coronavirus (COVID-19) has governments across Europe, Asia, Africa, Australia, North and Latin America quickly evaluating and issuing modified tax-related measures to help support business investments and providing...more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets.
Understand how new tax regulations transect...more
6/2/2020
/ Anti Tax Avoidance Directive (ATAD) ,
Business Operations ,
Business Taxes ,
Continuing Legal Education ,
Corporate Taxes ,
Dividends ,
Financing ,
Foreign Corporations ,
France ,
Germany ,
Holding Companies ,
International Tax Issues ,
Italy ,
New Regulations ,
Restructuring ,
Tax Liability ,
Tax Losses ,
Tax Planning ,
Transfer Pricing ,
UK ,
Webinars ,
Withholding Tax
The Coronavirus (COVID-19) has governments across Europe, Asia, Africa, Australia, Latin America and the United States quickly evaluating and issuing modified tax-related measures to help support business investments and...more
The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more
2/11/2020
/ Appeals ,
Audits ,
BEPS ,
Corporate Counsel ,
Corporate Taxes ,
Criminal Prosecution ,
EU ,
Foreign Subsidiaries ,
France ,
Google ,
Ireland ,
Non-Prosecution Agreements ,
OECD ,
Popular ,
Principal Place of Business ,
Search & Seizure ,
Settlement ,
Tax Authority ,
Tax Evasion ,
Tax Treaty ,
Value-Added Tax (VAT)
A recent McDermott round table on European health private equity generated key insights into the future of medtech, digital health, and data analytics, and identified opportunities for companies and investors.
Digital...more
12/20/2019
/ CFIUS ,
Digital Health ,
Digital Services Tax ,
Global Dealmaking ,
Healthcare ,
International Arbitration ,
Life Sciences ,
Medical Devices ,
Outbound Transactions ,
Private Equity ,
State-Owned Enterprises ,
UK Competition and Markets Authority (CMA)
Governments are starting to catch up with online businesses. Multinational clients that provide online advertising services, sell consumer data, or run online intermediary platforms should prepare themselves for the imminent...more
11/13/2019
/ Business Taxes ,
Data Protection ,
Digital Service Providers ,
Digital Services Tax ,
Double Taxation ,
Imports ,
Income Taxes ,
International Tax Issues ,
Jurisdiction ,
Online Advertisements ,
Online Marketplace ,
Online Platforms ,
Personal Data ,
Reimbursements ,
Retaliatory Tariffs ,
Search Engines ,
Social Media ,
Tax Planning
The French 3 Percent Distribution Tax: Claiming a Refund -
Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more
7/15/2015
/ Corporate Taxes ,
Dividends ,
Double Taxation ,
EU ,
France ,
Germany ,
HMRC ,
Income Taxes ,
Italy ,
Multinationals ,
Mutual Agreement Procedure ,
Required Documentation ,
Subsidiaries ,
Tax Avoidance ,
Tax Credits ,
Tax Penalties ,
Tax Refunds ,
Taxable Distributions ,
Transfer Pricing ,
Treaty on the Functioning of the European Union (TFEU) ,
UK
In This Issue:
- U.S. International Tax Policy: 10 Questions for 2015
- The New UK Diverted Profits Tax
- France Implements Horizontal Tax Consolidation
- China’s New General Anti-Avoidance Rules: An...more
3/5/2015
EU resident individual taxpayers who have paid French social taxes (contribution sociale généralisée (CSG), contribution au remboursement de la dette sociale (CRDS) and prélèvements sociaux) on France-originating real estate...more
Scope of The 3 Per Cent Tax -
The 3 per cent tax is levied on dividend distributions and/or deemed dividend distributions by French companies, French permanent establishments and other French entities that are liable...more
The annual filing imposed on trustees must be submitted by 15 June on new, dedicated forms published by the French tax authorities, and in the French language.
...more
The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies....more
France’s list of non-cooperative states and territories published in 2013 includes Botswana, Brunei, Guatemala, Marshall Islands, Montserrat, Nauru and, effective from 1 January 2014, Jersey, Bermuda and the British Virgin...more
France’s non-cooperative states and territories list for 2013 includes Botswana, Brunei, Guatemala, Marshall Islands, Montserrat, Nauru, Jersey, Bermuda and the British Virgin Islands (BVI). The tax consequences related to...more