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The Protocol introduces, among other things, changes to the applicable withholding tax rates in respect of payments of dividends and interest.

The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income.

Amount B aims to standardize the remuneration of related party distributors that perform baseline marketing and distribution activities in a manner that is aligned with the arm's length principle.

On 22 December 2021, the European Commission presented a proposal for a new directive to fight against the misuses of shell entities for improper tax purposes.

The Department of Justice has announced another program designed to identify United States taxpayers who have unreported foreign bank accounts.

On April 8, 2011, the Treasury and IRS issued Notice 2011-34 (the "Notice") which provides some, but not all, of the guidance foreign financial institutions need to satisfy their obligations under the Foreign Account Tax Compliance Act ("FATCA").

This Update highlights some of the principal new developments applicable to employee stock plans in selected jurisdictions worldwide.

"The One, Big, Beautiful Bill" (H.R. 1, 119th Congress) (the OBBB) is a tax package advanced as a part of the proposed Defending American Jobs and Investment Act.

Sending employees on temporary assignment to a foreign country without incurring host-country income taxes once seemed a simple matter for multinationals. But it's not so simple anymore.

The Organisation for Economic Co-Operation and Development and G20 member countries are developing a standardised approach to taxing the digital economy.

Income derived by a foreign subsidiary of a U.S. corporation from the sale of products is not generally subject to U.S. taxation on a current basis.

On November 2, 2011, the US Treasury Department released proposed regulations (the Proposed Regulations) under Section 892 of the Internal Revenue Code of 1986, as amended (the Code) that should facilitate the investment in private equity funds by sovereign wealth funds and other entities controlled by foreign governments.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

NUMBER OF THE WEEK: 8 percent. The increase in the total amount of corporate profits kept abroad, according to the latest analysis of securities filings by Bloomberg News.

On June 9, 2009, the IRS issued new final and temporary regulations (T.D. 9453) under the "anti-inversion"; rules of Section 7874 of Internal Revenue Code of 1986, as amended (the "Code").

If the bill is passed, it would deny the benefits of section 892 to several of the largest sovereign wealth funds by assets.

On July 17, 2018, Japan signed an Economic Partnership Agreement ("Japan-EU EPA") with the European Union ("EU"). Once the Japan-EU EPA is implemented, 99 percent of EU custom duties and 94 percent of Japanese customs duties will be eliminated.