International Updates
Under the 60-day rule in Cyprus, individuals are considered tax residents of Cyprus and benefit from the island's tax regime.
On December 10 2018, Portugal published Notice 144/2018 in the Official Gazette, announcing the new income tax treaty with Montenegro.
Russian legal entities that make capital gains from the sale of shares are eligible for a 0% tax rate, yet the criteria for satisfying this arrangement may not always be so simple.
Canada's Revenue Agency (CRA) confirmed in a recent technical interpretation (2017-071330117) that Canadian withholding tax can apply to the accrued (but unpaid) interest on a debt owed by a Canadian resident to a non-resident when the debt is assumed by another entity and such an assumption constitutes a "novation" of the debt obligation for purposes of the applicable commercial law.
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Sponsored by Fenwick & WestThe Ninth Circuit reversed, and then withdrew its reversal of, the Tax Court's unanimous 'reviewed by the court' decision in Altera Corp. v. Commissioner, 145 T.C. 91 (2015), and held in a 2-1 decision that Treas. Reg. § 1.482-7(d)(2), requiring related entities to share the cost of employee stock compensation (the 2003 Regulation) was a valid regulation. -
Sponsored by MDDPThe new rules concerning income tax on building regulations will enter into force on January 1 2019, with some relating to 2018.
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Sponsored by DLA Piper AustraliaIn recent weeks, we have seen important Australian tax developments that are relevant to multinationals and inbound investments. With many initiatives taking effect as early as January 1 2019, multinationals should consider the potential impact on their inbound and outbound Australian investments.
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