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Financial Services Industry › Tax Liability › International Tax Issues

King & Spalding

“Revenge Tax”

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Withholding Tax Rules Under Current Law - Current US tax law provides for a 30% withholding tax on interest paid by a US borrower to foreign lenders. However, many foreign lenders are exempt from this tax, either under the...more

Troutman Pepper Locke

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

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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

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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

DLA Piper

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

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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

Stikeman Elliott LLP

Tax Court’s Denial of a Bank’s GST/HST Rebate Claims Affirmed; No Issue Estoppel as Retroactive GST/HST Legislation Had Been...

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This dispute arose when the Canada Revenue Agency (“CRA”) reassessed President’s Choice Bank (“PCB”) for uncollected GST/HST on bundled supplies made to a major Canadian bank (the “Bank”) and denied the Bank’s rebate claims...more

Cadwalader, Wickersham & Taft LLP

Over the Horizon

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The resounding theme for the 2023 G20 summit, held on 9th and 10th September in India, has been “Vasudhaiva Kutumbakam” – an ancient Sanskrit phrase meaning “the world is one family.” The term perfectly juxtaposes...more

Stikeman Elliott LLP

Credit Card Rewards Program Expenses: Tax Court of Canada Doesn’t Buy $13.97 Million GST/HST Input Tax Credit Claim

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On June 27, 2023, the Tax Court of Canada (“TCC”) dismissed the appeal of a Schedule II bank (the “Bank”) regarding its entitlement to input tax credits (“ITCs”) for GST/HST payable on expenses incurred in connection with the...more

Stikeman Elliott LLP

Federal Court of Appeal Confirms Tax Court of Canada’s Decision: Supply of Right to Place and Operate ATMs is a Taxable Supply

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On June 8, 2023, the Federal Court of Appeal upheld a Tax Court of Canada decision that, by allowing a supplier of Automated Teller Machines (“ATMs”) to place and operate ATMs throughout its casino resort, a casino operator...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

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Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

White & Case LLP

Spain to tax acquisitions of shares of major Spanish listed companies

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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

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