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Walkers

Mid-year update: Increasing number of corporate migrations into Guernsey

Walkers on

Migration, redomiciliation, continuation - the process which has many names is increasing in popularity. Guernsey has experienced a notable increase in the inward migration of corporate vehicles from other jurisdictions....more

Allen Barron, Inc.

Expanding Your International Business to San Diego or the United States

Allen Barron, Inc. on

Are you considering expanding your international business to San Diego or the United States? Are you planning to start a new business entity to add to the existing constellation of your companies, or are you considering a...more

Seyfarth Shaw LLP

Hong Kong Launches Company Re-domiciliation Regime

Seyfarth Shaw LLP on

In a move to enhance Hong Kong’s status as a global business and financial hub, and to attract foreign companies to take advantage of Hong Kong’s taxation system and professional services–thereby encouraging investment and...more

Hone Maxwell

Why Some International Entrepreneurs Use U.S. LLCs Without Paying U.S. Tax

Hone Maxwell on

In the increasingly global world of online business, it’s not unusual for entrepreneurs, freelancers, and consultants to seek a business structure that supports international operations, offers stable banking options, and...more

Conyers

Economic Substance Declaration Filings – May 2025

Conyers on

The Economic Substance Act 2018 (the “Act”) requires Bermuda-based entities that are carrying on a “relevant activity” in a relevant financial period and entities claiming “non-resident entity” status under the Act to file an...more

Cadwalader, Wickersham & Taft LLP

Nordcurrent: Interpreting Anti-Abuse Rules

On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more

Allen Barron, Inc.

Offshore Real Estate Ownership and Tax Reporting Requirements

Allen Barron, Inc. on

What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more

Mayer Brown

Caractérisation d’un établissement stable dans le domaine du digital en présence d’une activité occulte

Mayer Brown on

Le Conseil d’Etat confirme l’existence d’un établissement stable et caractérise une activité occulte en l’absence de déclaration de cet établissement en France par application de l’article L. 169 du Livre des procédures...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

McDermott Will & Schulte

Exit tax for investement shares

Anyone who moves out of Germany and has investment shares or transfers them outside of Germany will have to pay taxes – even if the shares are not sold. Private investors in investment funds will have to pay taxes in the...more

Conyers

Cayman Entities and the Economic Substance Regime – Is Your Cayman Entity in Compliance?

Conyers on

As we gear up for the final quarter of 2024, this is an excellent time to review Cayman based entities with a financial year end of 31 December 2024 and consider the position of these entities with respect to the Cayman...more

Conyers

BVI Quarterly Corporate Update Q1 2024

Conyers on

Welcome to the first edition of our Quarterly Corporate Update for 2024 covering recent developments in the British Virgin Islands. The first quarter of 2024 saw continued strong activity in the BVI office. Our corporate...more

Arnall Golden Gregory LLP

AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders

In this episode, Mike Burke, AGG Corporate partner and leader of the Ireland & Northern Ireland practice, explores U.S. tax considerations for foreign businesses scaling to the U.S., including issues such as the branch...more

A&O Shearman

Luxembourg tax administration issues guidance on the tax treatment and reporting obligations of reverse hybrid entities

A&O Shearman on

On 9 June 2023, the Luxembourg tax administration (the LTA) issued circular L.I.R. n°168quater/1 (the Circular) providing long-awaited guidance on the application of article 168quater of the Luxembourg Income Tax Law (the...more

Freeman Law

Reviewing a Foreign Legal Structure

Freeman Law on

Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Jones Day

Dutch Limited Partnerships Attractive Alternative to Luxembourg and Irish Fund Structuring

Jones Day on

Proposed changes to Dutch tax law will make Dutch limited partnerships attractive private equity and venture capital fund and feeder fund alternatives to Irish and Luxembourg equivalents. A Dutch limited partnership...more

Orrick, Herrington & Sutcliffe LLP

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more

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