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1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother...more
Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER MICHIGAN LAW - I. STANDARD FORMS OF AGREEMENTS - A. Offers to Purchase that are accepted by sellers are the typical form of purchase contract for residential properties. The...more
Orrick's UK Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of...more
1. Types of business entities - Investors may choose from the following forms of corporate structure: - Limited liability company - Joint-stock company - Limited liability partnership - General partnership -...more
Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more
1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother company,...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER MICHIGAN LAW - I. STANDARD FORMS OF AGREEMENTS - A. Offers to Purchase that are accepted by sellers are the typical form of purchase contract for residential properties....more
On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more
1. Types of business entities - Investors may choose from the following forms of corporate structure: - Limited liability company - Joint-stock company - Limited liability partnership - General partnership ...more
On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more
In many respects, the Upper Tribunal’s decision in Hargreaves Property will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to...more
The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more
Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more
On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more
Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD)...more
The UAE has not imposed corporate taxes on profits of most corporations or other businesses historically. That said, the Government of UAE will be introducing corporate tax to be levied on businesses, effective for financial...more
Tax Litigation: The Week of March 14, 2022, through March 18, 2022 Hamilton v. Comm’r, T.C. Memo. 2022-21 | March 15, 2022 |Urda, J. | Dkt. No. 139-19L Pickens Decorative Stone, LLC v. Comm’r, T.C. Memo. 2022-22 | March 17,...more
Even without a German nexus, in cases of a licensing of right registered in Germany an application/disclosure before 30 June 2022 might be necessary. ..According to the German Federal Ministry of Finance (BMF) the...more