The EU’s second-highest court overturned a 2016 ruling ordering Apple to pay Irish tax authorities 13 billion euros for receiving undue tax benefits. Multinationals should beware of taking the ruling as a sign the world of international taxation is reverting to an earlier era.
On October 4, 2017, the Internal Revenue Service provided relief to residents of Puerto Rico and the US Virgin Islands who evacuated or could not return because of Hurricane Irma or Hurricane Maria.
In a recent post, we addressed the subject of what to ask before winding down a legal entity abroad. Here we look at what to expect after you’ve decided to move forward with dissolving an entity, and we explore some real-life examples.
There are real benefits to regularly reviewing an organization’s structure to uncover possible efficiencies, some of which might be brought on by dissolving certain legal entities. This post lists some important questions to ask when deciding whether to wind down an entity abroad.
US-based organizations often look to Hong Kong as a target country to gain a foothold into other major Asian markets. This post examines Hong Kong’s tax regime, administrative requirements and other factors to help readers determine if Hong Kong might be a suitable expansion destination for their organizations.
Today’s superstar athletes are powerful corporate brands, and they and their teams are looking for creative ways to reduce personal and corporate taxation. UK soccer clubs are compensating players and some coaches under a tax scheme that has some wondering if teams, players and coaches are effectively engaging in tax evasion.
Japan’s Ministry of Justice eliminated a longstanding law requiring foreign companies to appoint at least one resident of Japan as a representative director. This is welcome news for multinationals, but there are still substantial benefits associated with employing a local resident as a director.
On August 30, 2016, the European Commission found that Ireland granted illegal tax benefits to Apple Inc., and demanded that Apple repay €13 billion to Irish tax authorities. We provide a clear, concise summary of the situation and tell you what you need to consider in the wake of the ruling.
The Belgian Supreme Court has recently ruled that an "abnormal" or "gratuitous" benefit received by a company from a related company should be taxed without offsetting it against tax losses or other deductibles.
The government proposed that the Provident Fund tax benefit be reduced on April 1 so that only 40% of funds withdrawn would be tax-free. The government, however, has changed its position, and the Provident Fund will continue unchanged for now.
US companies are expanding into international markets at unprecedented rates. Whether through acquisition, organic growth, or a combination of both, companies are attempting to capitalize on market opportunities as quickly as possible. This desire for speed, however, can translate into overly aggressive large-scale expansion efforts that lack proper planning and ignore pertinent business risks and financial and administrative burdens. Over time, companies may become saddled with complex organizational structures that are inefficient, ineffective and costly to maintain. These needlessly complex legal entity structures can drain a company of much-needed cash, reduce profitability and introduce unnecessary risks.
The Danish government is considering a bill which will change the tax position on employee stock options where they will only be taxed at sale and with a maximum tax rate of 42% rather than the maximum 52% tax applied to salaries.