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Cozen O'Connor

What Canadian High Net Worth Families Should Know About the U.S. One Big Beautiful Bill

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The United States recently passed tax legislation called the One Big Beautiful Bill Act (OBBBA), a follow-up to the 2017 Trump tax cuts. While the bill is American, many Canadian families with cross-border ties, including...more

Holland & Knight LLP

A Look at the International Tax Changes in the One Big Beautiful Bill Act

Holland & Knight LLP on

The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more

WilmerHale

One Big Beautiful Bill Act

WilmerHale on

On July 4, 2025, the President signed into law the “One Big Beautiful Bill Act” (the “Act”). Among other things, the Act makes permanent many provisions of the 2017 Tax Cuts and Jobs Act (the “TCJA”) that otherwise would...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

Mintz - Tax Viewpoints

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

Mintz - Tax Viewpoints on

Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

Seward & Kissel LLP

Section 883 Tax Exemption for Cargo Shipping and Cruise Lines At Risk?

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Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more

DLA Piper

Brazil - VAT: Approval of the Supplementary Law on Tax Reform - Monthly Indirect Tax Alert – January 2025

DLA Piper on

On 16 January 2025, the President ratified Supplementary Law No. 214/2025, marking a significant step in Brazilian tax reform. This new law outlines the framework for the IBS, the CBS, and IS, while also establishing the IBS...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

A&O Shearman

Overview of the New Luxembourg Tax Measures to Improve Talent Attraction and Retention

A&O Shearman on

On December 20, 2024, the Luxembourg parliament adopted without material changes the tax relief package bill that we covered in a previous publication. Amongst others, this law introduces, as of fiscal year 2025, the...more

Cadwalader, Wickersham & Taft LLP

Missing the Target

In Target Group Ltd v HMRC [2023] UKSC 35 (“Target”), the United Kingdom’s Supreme Court has held that the loan services which the taxpayer company provided to a bank were not exempt from VAT. ...more

Cadwalader, Wickersham & Taft LLP

Hargreaves Property : What Does the Latest Decision Mean for UK Withholding Tax?

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 UK...more

Hogan Lovells

Welcoming Indonesia New Capital City – A Gift of Investment from Indonesia

Hogan Lovells on

On 15 February 2022, the Indonesian Government formalised its intention to relocate the capital from Jakarta to an undeveloped area in Kalimantan island, to be named “Nusantara” under Law No. 3 of 2022 regarding the State...more

Cadwalader, Wickersham & Taft LLP

Sub-Participations Are VAT Exempt Under EU Law

The Court of Justice of the European Union (the “CJEU”) held on 6 October 2022 in O. Fundusz lnwestycyjny zamknięty reprezentowany przez O S.A. (Case C-250/21) (the “O Fundusz case”) that the supply of services provided by a...more

Cadwalader, Wickersham & Taft LLP

UK Government Considers Changes to the Rules on Sovereign Immunity from Direct Taxation

The UK Government has recently consulted on a revised approach to sovereign immunity from direct taxation. The consultation was brought about owing to the view that whilst the scope of sovereign immunity-based exemptions has...more

Cadwalader, Wickersham & Taft LLP

EU Advocate-General Opined Sub-Participation Not within VAT Exemption for Granting Credit

In O. Fundusz lnwestycyjny Zamknięty reprezentowany przez O S.A. (Case C-250/21) (the “O Fundusz case”), Advocate-General Medina (the “AG”) of the Court of Justice of the European Union (“CJEU“) opined that the supply of...more

Morgan Lewis

Kazakhstan Stock Exchange: Significant Change to Taxation of Dividends on Certain Shares

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The rules for taxation of dividends in respect of shares that are included in the official listing of a stock exchange in Kazakhstan will significantly change as of 1 January 2023....more

Freeman Law

Tax Treaties and Exempt Income

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Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax Law Struggles To Keep Pace With the Proliferation of Cryptocurrency

Takeaways - The technical architecture of various cryptocurrencies makes it difficult to bring them within existing tax rules, even those designed to deal more generally with the digital marketplace. The U.S., U.K. and...more

Cadwalader, Wickersham & Taft LLP

A Look at the Biden Administration’s Fiscal Year 2022 Revenue Proposals

I. Introduction - On May 28, 2021, the Treasury Department released the Biden Administration’s Fiscal Year 2022 Revenue Proposals (the Greenbook). ...more

Proskauer Rose LLP

UK Tax Round Up - March 2021

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Spring Budget and Tax Day - After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more

Proskauer Rose LLP

UK Tax Round Up - January 2021

Proskauer Rose LLP on

UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more

Goodwin

Luxembourg: The EU Parent Subsidiary Directive And Gibraltar

Goodwin on

On 1 December, 2020, the Luxembourg tax authorities issued circular L.I.R 147/2, 166/2 and eval. n°63 on the application of EU Directive 2011/96 on the common system of taxation applicable in the case of parent companies and...more

Proskauer Rose LLP

UK Tax Round Up - November 2020

Proskauer Rose LLP on

UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more

Proskauer Rose LLP

UK Tax Round Up - December 2018

Proskauer Rose LLP on

UK Developments - Taxpayer succeeds in judicial review case against HMRC - On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK)...more

Holland & Knight LLP

Exclusión del IVA en la Importación y Enajenación de Computadores en Colombia

Holland & Knight LLP on

Por considerarlo de su interés, le informamos que el 10 de septiembre de 2018 el Ministerio de Hacienda y Crédito Público en Colombia divulgó un proyecto de Decreto "Por el cual se modifica el Decreto 1625 de 2016 Único...more

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