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Cross-Border Transactions Tax Planning

Hone Maxwell

The Benefits of Using Both a CPA and a Tax Attorney

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A frequent question we get from clients and colleagues is if a tax attorney or certified public accountant (CPA) — or both — are needed. ...more

Hogan Lovells

IRS reduces barriers to redomiciliations

Hogan Lovells on

On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more

Allen Barron, Inc.

IRS and State Tax Complications of Offshore Investments

Allen Barron, Inc. on

What do you need to know about the IRS and state tax complications of offshore investments? It is common to have international investments in your portfolio, not to mention business interests. How do you navigate the...more

Cooley LLP

Key Trends and Considerations in Cross-Border Life Sciences Partnering-Licensing and NewCo Transactions Between Chinese and...

Cooley LLP on

Over the past decade, the landscape of cross-border partnering in the life sciences sector has undergone a dramatic transformation, particularly in transactions between Chinese biotech companies and their US and European...more

A&O Shearman

Key considerations for forming and operating a joint venture in the U.S.

A&O Shearman on

Each of these items will help ensure that a U.S.-based joint venture (JV)—especially one in a regulated industry with cross-border aspects—is set up and operated on solid legal, compliance, and tax footing. By diligently...more

Hone Maxwell

Cross-Border Collaboration Success: Five Top Strategies

Hone Maxwell on

In the United States, we drive on the right side of the road. In Singapore, cars drive on the left. Mexico, meanwhile, has its own road signs and speed limits, which sometimes are viewed as suggestions....more

Offit Kurman

Not Knowing the Tax Implications of How Your Client is Classified?

Offit Kurman on

Welcome to Lost in Translation: Blunders in International Estate Planning; in this blog series, I will delve into the rarified world of international estate planning, shedding light on possible pitfalls and slip-ups....more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Non-U.S. Persons Investing in U.S. Capital Markets

BakerHostetler on

Non-Americans who wish to purchase U.S. stocks and other financial assets should be aware of the tax consequences of investing here. George McCormick discusses this issue and more....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

Brownstein Hyatt Farber Schreck

OECD Announces Global Tax Deal

The Organization for Economic Cooperation and Development (OECD) announced earlier today that 136 countries reached agreement on the Inclusive Framework on Base Erosion and Profit Shifting. The two-pillar framework would...more

Freeman Law

[Webinar] Updates: IRS Tax Enforcement, Taxation of Settlements, and Cross-Border Tax Planning - August 31st, 3:00 pm CT

Freeman Law on

Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

Cadwalader, Wickersham & Taft LLP

A Peek Behind the Curtain: IRS Musings on Spinoff Ruling Procedures

Speaking at several tax conferences this month, several senior IRS officials, including the Associate Chief Counsel, Corporate, discussed the nuances of the device requirement for spinoffs and signaled a willingness to relax...more

Morgan Lewis

German Taxation of IP Rights

Morgan Lewis on

IP rights with a nexus to Germany can create a variety of tax issues under German tax law. These include aspects of German or foreign IP rights generating “German source income,” questions of withholding tax obligations, a...more

Katten Muchin Rosenman LLP

DAC6: Adieu to EU

On the eve of the UK's exit from the EU on 31 December 2020, the UK Government published the concise but game-changing piece of legislation, 'The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2)...more

Morgan Lewis

Changes to UK DAC 6 Reporting Requirements

Morgan Lewis on

Coinciding with the end of the UK-EU Brexit transition period, the United Kingdom has dramatically reduced the scope of DAC 6 reporting obligations in the United Kingdom. ...more

McDermott Will & Schulte

[Webinar] International Tax Transparency Update - November 18th, 3:00 pm GMT

McDermott Will & Schulte on

Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more

McDermott Will & Schulte

Policy Outlook: How The 2020 Election Outcomes Will Impact Your Business - Health Policy

In this session, health law policy authorities discussed changes likely in 2021 in a Biden Administration and how these changes will impact business objectives and strategies for health industry stakeholders...more

McDermott Will & Schulte

[Webinar] Policy Outlook: How The 2020 Election Outcomes Will Impact Your Business - November 5th, 12:00 pm - 2:15 pm EST

McDermott Will & Schulte on

Are you prepared for the critical impacts of the US election outcome to you and your business in 2021 and beyond? Join McDermott’s lawyers and our policy and lobbying team for perspective on the effects of administration...more

Morgan Lewis

Beware States Offering Unilateral Advance Pricing Agreements for Transfer Pricing

Morgan Lewis on

As state revenue agencies train their auditors in traditional IRC §482 transfer-pricing methodologies or outsource transfer-pricing audits to third-party specialists, a recent initiative by the Indiana Department of Revenue...more

Jones Day

JONES DAY PRESENTS®: EU Mandatory Disclosure Rules (DAC 6)

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DAC6, the European Union's new disclosure regime, imposes the reporting of cross-border tax arrangements for multinational enterprises in 28 European countries. Jones Day partners Florian Lechner (Frankfurt) and Carlos...more

Proskauer Rose LLP

UK Tax Round Up - June 2020

Proskauer Rose LLP on

UK COVID-19 Developments - HMRC updates its trading activities guidance - HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more

McDermott Will & Schulte

[Webinar] DAC6 - Are You Ready? - June 10th, 4:00 pm BST

In our latest interactive webinar we will discuss DAC6 – the EU Directive on reportable cross-border tax arrangements – and its impact on business. The importance of DAC6 cannot be overstated. As an intermediary,...more

White & Case LLP

DAC6 reporting delay proposed by EU Commission due to COVID-19

White & Case LLP on

DAC6 summary - Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Lessons From 2019: Impact of BEPS on Cross-Border Transactions

In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more

McDermott Will & Schulte

Weekly IRS Roundup December 23 – 27, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

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