News & Analysis as of

Investment International Tax Issues

Morgan Lewis

Government Draft of Annual Tax Act 2024 Adopted

Morgan Lewis on

The Federal Cabinet adopted the government draft of an Annual Tax Act 2024 (JStG 2024) on June 5, 2024. The government draft largely corresponds to the draft bill of May 17, 2024 and contains a large number of very different...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Mayer Brown

Public Notice for Adhesion to Tax Settlement: Tax debts Related to Subsidies for Investments

Mayer Brown on

On May 16, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) and the Office of Attorney-General of the National Treasury (“PGFN”) jointly published the Public Notice of Transaction for Adhesion in the Tax...more

Jones Day

Dispute Resolution Under OECD’s “Pillar Two” 15% Global Minimum Tax Remains Unclear

Jones Day on

In October 2020, the Organization for Economic Co-operation and Development (“OECD”) Secretariat released a report addressing its “Pillar Two” blueprint for an overhaul of the international tax system. Pillar Two provides for...more

Mayer Brown

Brazil’s New Tax Rules for Infrastructure Investments

Mayer Brown on

Below we list some key tax legislative changes that are relevant to new investments in infrastructure projects and that are already in force or have been announced by the government and are under discussion in the National...more

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

Allen Barron, Inc. on

Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Hogan Lovells

Changes under the Future Financing Act – Employee equity finally future-proof?

Hogan Lovells on

With the recently published draft of a "Future Financing Act", the federal government has reacted to the criticism on the tax treatment of equity instruments granted to employees. From the perspective of young companies, the...more

Hogan Lovells

Änderungen durch das Zukunftsfinanzierungsgesetz – Mitarbeiterbeteiligung endlich zukunftsfest?

Hogan Lovells on

Mit dem kürzlich veröffentlichten Entwurf eines „Zukunftsfinanzierungsgesetzes“ hat die Bundesregierung auf die Kritik zur steuerlichen Behandlung von Mitarbeiterbeteiligungen reagiert. Die vorgesehenen Änderungen sind aus...more

Skadden, Arps, Slate, Meagher & Flom LLP

Exploring Potential Investor-State Treaty Challenges to the OECD’s Pillar Two Model Tax Rules

Adoption of the OECD Pillar Two model rules implementing accords on a global minimum corporate tax rate may result in anomalous or unfair results for some multinationals. Protections available under investment treaties,...more

Dechert LLP

Collateralized Fund Obligations (CFOs): The Technicolor Dreamcoat of Fund Finance

Dechert LLP on

Over the past several years as Collateralized Loan Obligations (“CLOs”) reached new and dizzying heights in issuance volume, CFOs have been quietly, and under the radar, gaining market acceptance and momentum among asset...more

Dechert LLP

Proposed reforms to sovereign immunity from UK direct tax – Government Consultation

Dechert LLP on

On 4 July 2022, the government published a consultation document calling for engagement in relation to proposed reforms to clarify who is entitled to benefit from sovereign immunity and also to restrict the availability of...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

McDermott Will & Emery

International News: Spotlight on Tax

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

Cadwalader, Wickersham & Taft LLP

OECD Cryptoasset Reporting Framework

On 22 March 2022, the Organisation for Economic Co-operation and Development (“OECD”) published a public consultation document proposing new and amended reporting requirements with respect to cryptoassets and electronic-money...more

Orrick, Herrington & Sutcliffe LLP

Bilancio di Previsione dello Stato per l'anno finanziario 2020

(Legge 27 dicembre 2019, n. 160 pubblicata in Gazzetta Ufficiale serie generale 304 del 30 dicembre 2019). ...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

Orrick, Herrington & Sutcliffe LLP

The Simple Investment Company - A New Structure for the Investment and Financial Support to Italian SMEs

In recent years, in Italy a constant growth in investments to emerging Italian companies (i.e. the "start-ups") has taken place. ...more

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