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Financial Institutions International Tax Issues

Carey Olsen

CRS 2.0 amendments to the OECD’s Common Reporting Standard

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The Common Reporting Standard (CRS) was developed by the Organisation for Economic Co-operation and Development (OECD) to promote tax transparency by enabling tax authorities in one jurisdiction to receive information...more

Hone Maxwell

Understanding FATCA and Its Impact on Foreign Financial Institutions: Why Finding Financial Services as an American Abroad Can Be...

Hone Maxwell on

As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more

Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

Troutman Pepper Locke on

In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

Troutman Pepper Locke on

Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

Walkers

Moving to the Channel Islands: A guide for asset managers

Walkers on

Jersey and Guernsey have long been recognised as leading international investment hubs, offering asset managers a compelling mix of professional and lifestyle advantages....more

DLA Piper

Netherlands - VAT: Dutch Attorney General (AG) Issues Conclusion on Impact of Receiving VAT Exempt Interest Income on VAT Recovery...

DLA Piper on

Back in November 2023, the Amsterdam High Court ruled that the interest received by X BV (a notary firm) for funds in its trust account qualifies as VAT exempt turnover. According to the High Court, the interest received by X...more

Blake, Cassels & Graydon LLP

Budget fédéral de 2022 – Présentation de certaines mesures fiscales

Le 7 avril 2022 (le « jour du Budget »), la ministre des Finances du Canada a présenté le budget fédéral de 2022 (le « Budget 2022 »). Certains contribuables ont peut-être été soulagés de constater que le Budget 2022 ne...more

Blake, Cassels & Graydon LLP

2022 Federal Budget: Selected Tax Measures

On April 7, 2022 (Budget Day), the Minister of Finance introduced Canada’s 2022 Federal Budget (Budget 2022). While taxpayers may be relieved that Budget 2022 does not include an increase to the capital gains inclusion rate...more

Freeman Law

OECD Proposes Rules for Intermediary Crypto-Asset Reporting, Due Diligence

Freeman Law on

On March 22, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued proposed rules for the collection and exchange of information on transactions involving crypto-assets. The OECD intends for these...more

Sullivan & Worcester

Structuring trade finance transactions using SPVs: Balancing the risks and rewards

Sullivan & Worcester on

At the latest Trade & Export Finance webinar, Sam Fowler-Holmes, a partner in the Trade & Export Finance Group at Sullivan's London office, gave some valuable insight into what to consider before using a special purpose...more

White & Case LLP

Spain to tax acquisitions of shares of major Spanish listed companies

White & Case LLP on

The Spanish Official Gazette published last October 16th legislation enacting a new indirect Tax on Financial Transactions levied, at 0.2%, on the acquisition of shares of major Spanish listed companies irrespective of the...more

Jones Day

Italy: 110% Tax Deduction Enacted for Certain Energy and Anti-Seismic Works on Existing Buildings

Jones Day on

The Situation: For years, the Italian tax system has provided for certain tax deductions from income taxes in case of building restoration works. The Result: The tax deduction from income taxes has now been increased to...more

Perkins Coie

Blockchain Week in Review - January 2020 #3

Perkins Coie on

U.S. Developments - Federal and State Regulatory Developments - Bill in Hawaii State Senate Addresses Digital Assets Including Authorization for Banks to Serve as Qualified Custodians - SB 2594 before the Hawaii...more

McDermott Will & Schulte

Brexit Update - March 2019

SPECIAL REPORT - BREXIT: CHALLENGES AND OPPORTUNITIES - In this report, we explain some of the key legal implications associated with the United Kingdom leaving the European Union (EU) without a deal for future...more

Womble Bond Dickinson

The Juncker Presidency and EU Tax Policy

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In this reprint of his 2014 article, Rick leveraged his past working relationship to Jean Claude Juncker to accurately predict the unprecedented tax policy success of the Juncker Commission. Jean-Claude Juncker,...more

Akin Gump Strauss Hauer & Feld LLP

Swiss Tax Law Changes: Federal Act on Tax Reform and AHV Financing (TRAF)

• Switzerland’s privileged taxation of companies is no longer in line with international standards. • In 2017, the first attempt to abolish the internationally criticized regime was clearly rejected by Swiss voters. • On 28...more

Latham & Watkins LLP

Multinational Financial Groups After the U.S. Tax Reform: Selected Inbound and Outbound Issues

Latham & Watkins LLP on

Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more

Dorsey & Whitney LLP

China’s Greater Bay Area Puts Hong Kong In The Lead As Super Connector To The World

Dorsey & Whitney LLP on

China’s open door policy is further opening up to welcome the world for business. The country is now building a landmark megalopolis on its southern coast with the name the “Greater Bay Area” (the “GBA”). ...more

Jones Day

The Year in Bankruptcy: 2017

Jones Day on

The initial year of the Trump administration colored much of the political, business, and financial headlines of 2017, both in the U.S. and abroad. Key administration-related developments in 2017 included U.S. withdrawal from...more

Robins Kaplan LLP

Your daily dose of financial news The Brief – 4.6.16

Robins Kaplan LLP on

Talk about a regulation with teeth. Within days of the Treasury Department announcing new rules meant to discourage corporate tax inversion deals, Pfizer and Allergan announced they were scrapping their planned $152 billion...more

McGuireWoods LLP

OECD Releases Final BEPS Recommendations – Now What?

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On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more

Sheppard Mullin Richter & Hampton LLP

[Event] Breakfast With Your Finance & Bankruptcy Lawyers: The Risks and Rewards of Financings in Europe - May 13, New York, NY

This breakfast session is jointly presented by Sheppard Mullin and Bird & Bird LLP, and will look at the key issues to consider when structuring financings involving European counterparties and examine whether there are real...more

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