Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
Exploring Carried Interest in Upper Tier Private Equity Structures — PE Pathways
Insider Transaction Traps for the Unwary
Essentials for Balancing Taxes and Legal Risk
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Real Estate and Tax
Maximizing Financial Growth: Insights on HSAs and Smart Investment Strategies with Shaun Eddy
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
5 Key Takeaways | Income Tax Jeopardy! A Potpourri of Hot Topics
REFRESH: Loot and Private Foundation Rules – Part 2
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention
Domestic Tax Planning - Podcast with Janathan Allen
Tax Liability Insurance Products: A Hidden Gem in the Transactional Lawyer’s Tool Box
JONES DAY PRESENTS®: Tax Implications of Telehealth as Remote Services Become Norm
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
Germany’s Federal Fiscal Court (BFH) has decided on the legitimacy of double assessment of real estate transfer tax in share deals. Tax authorities have taken the view that the acquisition of at least 90% of shares in a...more
In two rulings, the Federal Fiscal Court (BFH) ruled in favor of the taxpayer on the requirements for a consolidated tax group for income tax purposes. Managing holding partnership as controlling company (judgment of November...more
The German Federal Fiscal Court (BFH) confirmed its case law according to which the commercial infection of an upper-tier partnership pursuant to Section 15 para. 3 no. 1 sentence 1 alt. 2 German Income Tax Code...more
Dividends from shares are taxable for shareholders, even if the dividends do not remain with them economically. This (not entirely new) finding can be gleaned from a recent Federal Fiscal Court (BFH) ruling in which the...more
The issue of the taxability of intra-group supplies in the context of a VAT group has been of concern to taxpayers for many years. The starting point was the question of whether a VAT group existed between a foundation under...more
The Federal Cabinet adopted the government draft of an Annual Tax Act 2024 (JStG 2024) on June 5, 2024. The government draft largely corresponds to the draft bill of May 17, 2024 and contains a large number of very different...more
Summary - ..According to the German Federal Ministry of Finance (BMF) the licensing of rights registered in a German register is subject to limited tax liability, even if no further German nexus exists. ..Depending...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
For months now the treatment of licence fee income generated in Germany under licence agreements concluded between foreign companies where the right granted is merely listed in a public register in Germany has been causing...more
Draft bill published on 19 November 2020 offers hope that an unnecessary tax discussion may be brought to an end A German tax issue has been causing great uncertainty among international corporates since spring 2020: Are...more
In a decree published November 6, 2020, the German tax authorities confirmed their view that transactions between non-German parties (e.g., between two U.S. companies) are generally taxable in Germany, if this income is...more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more
On 13 March 2020, the German government agreed on a far-reaching package of measures to protect companies and businesses in the German market. The central message is that the Federal State (Bund) and the provinces...more
In a recently published decision, the German Federal Tax Court (Bundesfinanzhof, BFH) clarified for the first time that a remuneration for the complete transfer of rights in the context of a “total buy out” against a one-off...more
Recently the German legislature passed a new law, exempting extraordinary profits created by the waiver of claims under restructurings from income tax liability. ...more
On August 10, 2018, the German government officially filed a new tax bill with the German parliament that is directed against VAT avoidance relating to supplies of goods with a German nexus over electronic ("online")...more
Yesterday the German Federal Ministry of Finance (Bundesfinanzministerium) released a draft circular on the German tax treatment of royalties paid for software and database licenses granted by non-resident licensors....more
The German and international financial industries and their advisors have come under new pressure to investigate so-called 'cum/ex' trades conducted between 2000 and 2012. For many years, tax authorities and criminal...more
Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more
Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more
IF A SETTLEMENT AGREEMENT IS SILENT, A DEFENDANT IS NOT REQUIRED TO ‘GROSS UP’ THE SETTLEMENT, AND THE PLAINTIFF WILL SUFFER THE WITHHOLDING TAX BURDEN. What happens when settling parties agree that the defendant will...more