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

Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC

Pillar two helps PwC tax and legal services revenues rise

Increasingly complex reporting requirements contributed towards the firm’s growth in tax, it said

Sam Sholli, October 28 2025

Direct Tax

The current UK tax landscape and future developments

Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict

Aurell Taussig, October 28 2025

Direct Tax

A taxing week: The UK government’s Budget won't fix its popularity crisis

The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget

Sam Sholli, October 24 2025

Awards

Deloitte, DLA Piper win headline honours at ITR Americas Awards

The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club

Sam Sholli, October 24 2025

Direct Tax

This week in tax: Netflix shares fall after $619m tax dispute with Brazil

The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles

Sam Sholli, October 24 2025

Transfer Pricing

HSF Kramer client Oracle scores Australia MAP court win

Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure

Sam Sholli, October 22 2025

Direct Tax

EU facing ‘huge pressure’ to accommodate US on pillar two: expert

If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests

Sam Sholli, October 21 2025

Direct Tax

India and pillar two: implementation challenges and the road ahead

If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues

Sameer Sharma, October 21 2025

Rankings analysis

World Tax Rankings 2026: DLA Piper, Deloitte dominate EMEA promotions

As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses

Tom Baker, October 20 2025

Direct Tax

A taxing week: Why tax is now front-page news

Firms are spending serious money to expand their tax advisory practices internationally – this proves that the tax practice is no mere sideshow

Tom Baker, October 17 2025