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Tax Liability Tax Planning International Tax Issues

Allen Barron, Inc.

When Do You Need a Tax Attorney

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One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more

Offit Kurman

Overlooking the Role of Cash as King

Offit Kurman on

Welcome to “Lost in Translation: Blunders in International Estate Planning.” This blog series explores the rarified world of international estate planning, uncovering potential pitfalls and providing insights to navigate the...more

McDermott Will & Emery

IRS Roundup February 17 – March 14, 2025

McDermott Will & Emery on

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

Seward & Kissel LLP

Section 883 Tax Exemption for Cargo Shipping and Cruise Lines At Risk?

Seward & Kissel LLP on

Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more

DLA Piper

Chile's Internal Revenue Service Publishes It's 2025 Tax Schemes Catalog

DLA Piper on

Each year, the Internal Revenue Service of Chile (SII) updates its Tax Schemes Catalog. This guide contains a list of operations that may be declared elusive by applying the General Anti-Elusiveness Rule. The catalog's...more

IR Global

Stamp Duty Land Tax Changes from April 2025

IR Global on

Stamp Duty Land Tax Changes from April 2025: What Buyers Need to Know - From 1st April 2025, significant changes to Stamp Duty Land Tax (SDLT) will take effect, impacting buyers across England and Wales. These adjustments...more

Procopio, Cory, Hargreaves & Savitch LLP

Understanding Tariffs and Strategies for Mitigating Their Impact

In recent months, tariffs have become a significant concern for businesses importing goods, particularly in relation to trade agreements between the U.S., Mexico, and Canada, as well as with other countries. The U.S....more

DLA Piper

Belgium - VAT: New Belgian Circular Letter on the VAT Implications of Credit Insurance - Monthly Indirect Tax Alert – January 2025

DLA Piper on

Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...more

DLA Piper

Germany VAT - VAT Grouping: Final Verdict of the German Federal Fiscal Court in Finanzamt - Monthly Indirect Tax Alert – January...

DLA Piper on

The issue of the taxability of intra-group supplies in the context of a VAT group has been of concern to taxpayers for many years. The starting point was the question of whether a VAT group existed between a foundation under...more

Mayer Brown

Positionnement du Gouvernement devant le Parlement lors de lexamen a venir du nouveau projet de loi de finances pour 2025

Mayer Brown on

1.  CONTEXTE - Après la motion de censure du 4 décembre 2024 ayant entraîné le rejet du projet de loi de finances pour 2025, les discussions sur le projet avaient cessé....more

DLA Piper

Italy - VAT: Italy Broadens Digital Services Tax Scope - Monthly Indirect Tax Alert – January 2025

DLA Piper on

Company belonging to Euro 750 Mio Group, will pay DST regardless of their digital service turnover in Italy. ...more

Mayer Brown

Siège de direction effective : la recherche de la substance de l'entreprise et du lieu de prise de décision stratégique

Mayer Brown on

La cour administrative d'appel de Paris vient remettre en cause la localisation du siège de direction effective d'une société localisée au Royaume-Uni en recherchant le lieu effectif de prise de décisions stratégiques et en...more

Mayer Brown

Obligations convertibles inverses et abus de droit

Mayer Brown on

Le Conseil d'Etat considère que la mise en place d'actions convertibles inverses accompagnées de divers contrats d'option de vente et d'achat peut être constitutive d'un abus de droit fiscal sur le fondement de l'article L....more

Davies Ward Phillips & Vineberg LLP

Selected US Tax Developments

Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought. When an individual ceases to be resident in...more

Husch Blackwell LLP

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

Husch Blackwell LLP on

A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Proskauer - Tax Talks

Trump Administration Disavows the OECD Global Tax Deal

Proskauer - Tax Talks on

On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect...more

K&L Gates LLP

The Inside Basis: Tax Insurance in Luxembourg

K&L Gates LLP on

In our second episode of The Inside Basis, Randy Clark is joined by Marion Zeller, a tax partner in our Luxembourg office, and David Mussche, an associate director with Howden M&A's tax team, to discuss the state of tax...more

Cooley LLP

UK Government Sets Tax Agenda

Cooley LLP on

On October 30, 2024, the Labour government delivered its first Budget since assuming power in July 2024. The Budget is the main annual fiscal event in the UK, and yesterday’s announcements were an important opportunity for...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: U.S. Tax Reporting for Americans That Live Overseas and Voluntary...

BakerHostetler on

Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more

Cadwalader, Wickersham & Taft LLP

Not Yet Fixed in Place

In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more

Freeman Law

National Taxpayer Advocate Calls Out IRS on International Information Return Penalties

Freeman Law on

In a blog post on May 21, 2024, National Taxpayer Advocate Erin Collins called for the IRS to cease its systemic assessment of international information return penalties and for Congress to amend the Internal Revenue Code to...more

Hogan Lovells

Italian Tax Bonus Decree: what's new on the Superbonus scheme

Hogan Lovells on

Through the conversion of Law Decree No. 39/2024 into Law No. 67 of 23 May 2024 (the "Tax Bonus Decree"), the Parliament has now approved a number of restrictions substantially limiting the benefits of the so-called...more

Mayer Brown

Tax Law Highlights | Brazilian Tax Reform And Expectations For Its Regulation

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The Brazilian Tax Reform on consumption was enacted through Complementary Amendment No. 132/2023, which unified the main taxes on the consumption of goods and services in the form of a Dual VAT and through the creation of a...more

Latham & Watkins LLP

Restructuring Plans and Tax Liabilities A More Assertive HMRC

Latham & Watkins LLP on

Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more

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