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

Direct Tax

Beyond compliance theatre: Indonesia’s new era of tax transparency

With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach

Gitarani Prastuti , February 18 2026

Direct Tax

Why one tax firm is happy for associates to leave

In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment

Tom Baker, February 18 2026

Direct Tax

HMRC issues new guidance for online tax adviser registration system

Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said

Sam Sholli, February 17 2026

Direct Tax

Pillar two not hollowed out by side-by-side deal: US tax leader

Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR

Sam Sholli, February 16 2026

Direct Tax

Baker Tilly International appoints new global head of tax

Ian Halligan previously led Baker Tilly’s international tax services in the US

Sam Sholli, February 16 2026

Direct Tax

What Corporates Want 2025 840x473 article header (1).png

A taxing week: DEI was slipping down the US agenda with or without Trump

Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president

Tom Baker, February 13 2026

Direct Tax

Close-up of handshake of businesswoman and businessman

This week in tax: McDermott, BakerHostetler bolster US tax partner benches

The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom

Sam Sholli, February 13 2026

Direct Tax

Tax Justice Network slams ‘shameless’ ICC report amid UN negotiations

The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said

Sam Sholli, February 12 2026

Transfer Pricing

Morgan Lewis lures Baker McKenzie’s Americas tax leader in Washington DC

Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010

Sam Sholli, February 12 2026

Transfer Pricing

‘Aspirational’ MAP manual should be ‘go-to’ for taxpayers: OECD expert

While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’

Sam Sholli, February 11 2026