Sovereign immunity: A US and European view

February 01 2012

With the US recently proposing changes to the regulations under section 892 of the US Internal Revenue Code concerning investment through controlled entities by foreign governments including typical sovereign wealth funds, Peter Blessing and Ansgar Simon of Shearman & Sterling in New York provide an update on the US position and briefly compare the overall approach taken in the US with that taken in the UK, France and Germany.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Transfer Pricing

Copenhagen (Nyhavn district) in a sunny summer day

Denmark v EET Group case sets important precedent, say experts

The judgment, which saw Denmark's Supreme Court rely on OECD TP guidance, sets aside more than 15 years of consistent administrative practice, experts have told ITR

Sam Sholli, July 31 2025

Direct Tax

Why Belgium’s exit tax rules could come under fire in the courts

Belgium’s new coalition government has gone ahead with a new exit tax regime that could land it in the courts.

Ralph Cunningham, July 30 2025

Direct Tax

Proposed Brazil digital services tax would likely hit consumers, experts suggest

Brazil’s government has not officially framed the bill as a countermeasure amid trade tensions with the US, but the move is being considered as part of Brazil’s strategic response, one expert tells ITR

Sam Sholli, July 30 2025

Direct Tax

Income tax considerations for foreigners forming charitable foundations in India

Understanding India’s income tax landscape can help charities ensure compliance, optimise tax benefits, and enhance their impact, writes Raghav Bajaj of Khaitan & Co

Raghav Bajaj , July 29 2025

Indirect Tax

‘Brazil is not for amateurs’: Brazilian advisers praised for robust client service

Tax advisers in Brazil are rising above the country’s notoriously complex tax system to deliver high-quality advisory services, ITR’s exclusive in-house data reveals

Tom Baker, July 28 2025

Direct Tax

Holland & Knight tops the hiring charts again: ITR’s half-year Talent Tracker data

ITR’s data has highlighted the US firm’s ambition to become America’s ‘premier’ tax player via a concerted partner recruitment strategy

Tom Baker, July 25 2025

Direct Tax

This week in tax: A&M Tax launches Indonesia practice with ex-KPMG managing director

Jaap Zwaan’s arrival continues a recent streak of A&M Tax investing in the region; in other news, the US and Japan struck a deal that significantly lowered tariff rates

Tom Baker, July 25 2025

Transfer Pricing

Who gets taxed when no one’s there? AI, presence, and profit allocation

In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present

Leonard Wagenaar, July 24 2025

Transfer Pricing

French TP case highlights transaction scrutiny trend: experts

France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard

Sam Sholli, July 24 2025

Direct Tax

Washington DC Capitol view on cloudy sky background

US corporate investors back PCbCR despite government snub: FACT director

In an exclusive interview with ITR, Ian Gary calls for a central public CbCR database and bemoans the US’s lack of involvement in international tax transparency

Tom Baker, July 23 2025