The US IRS today issued its first set of proposed regulations on the global intangible low-taxed income (GILTI) provisions added in the . . .
GILTI rules particularly onerous for non-C corporation CFCControlled Foreign Corporations (CFCs) are a fundamental concept in international taxation, referring to foreign companies that are under the control of domestic shareholders. Control is typically established when residents of a country, either individually or collectively, own more than a specified percentage of a foreign company’s shares, voting rights, or have the ability to exert substantial influence over its decision-making.... More shareholders McDermott Will & Emery USA February 9 2018 Summary The recently enacted tax reform legislation significantly expanded
April/May 2015[1] Impact of FATCA on Cook Islands Entities[2] TABLE OF CONTENTS Background The key differences between FATCA and IGA Models 1 and 2
*For clarity, the term Double Tax TreatyA Double Taxation AgreementA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More (DTAA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More), also known as a Double TaxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands of different taxpayers, and juridical double taxation, where the same taxpayer is taxed on the same income in more than one country. Double... More Treaty (or a Tax TreatyA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More), is an international
US 2018 Tax Reform Bill H.R.1 sections 14201 and 14202 on GILTI US 2018 Tax Reform us-tax-reform-context-new-tax-concepts-and-impact-on-your-business-models A US taxpayer, if you own shares in
COMMENT Tax arbitration via new double tax treaties is on the increase. Hence, knowledge of international arbitration is important. Take a look at the following
Responses