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1
State + Local Tax Insights: Summer Issue 2019
Gone are the days that employees work from only one location from 9:00 a.m. to 5:00 p.m. With employees traveling throughout the U.S., and in many instances
United States
8 Oct 2019
2
Challenges Of A Mobile Workforce
Gone are the days that employees work from only one location from 9:00 a.m. to 5:00 p.m. With employees traveling throughout the U.S.
United States
23 Sep 2019
3
MoFo New York Tax Insights, Vol 10, Issue 9
After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new apportionment rules
United States
5 Sep 2019
4
Total Buyout & Copyrights – Highest German Tax Court Confirms Application Of German Withholding Tax
Under German tax law, remunerations paid abroad by persons/companies resident in Germany for the "temporary" transfer of rights/grant of exploitation rights are subject ...
UK
5 Jun 2019
5
The UK Double Tax Treaty Passport Scheme – Changes For The UK Loan Market
The UK Double Tax Treaty Passport ("DTTP") scheme has recently been extended by HM Revenue & Customs ("HMRC") to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme.
UK
10 Jul 2017
6
Tax Talk: Volume 10, Issue 1
We held up Tax Talk this quarter in order to bring you the latest on the Trump administration's tax reform plans.
United States
15 May 2017
7
IRS Guidance For Implementation Of The Section 871(M) Regulations
On December 2, 2016, the IRS released an advance version of Notice 2016-76 and followed through on its promise to provide taxpayers with guidance for complying with final and temporary regulations...
United States
13 Dec 2016
8
European M+A News - Winter 2016
Inbound investment structures seeking to acquire a German or UK corporation should take into account the potential taxation of both the local entity and the shareholder.
European Union
16 Feb 2016
9
The Private Placements Withholding Tax Exemption
The Finance Act 2015 introduced an exemption from a borrower's obligation to withhold tax from interest payments arising on qualifying private placements.
United States
7 Jan 2016
10
Extenders Bill Puts An End To Tax-Free REIT Spinoffs But Includes A Number Of Favorable Changes To The Taxation Of REITs
On December 18, 2015, the President signed the Omnibus Appropriations Act (the "Act") into law.
United States
6 Jan 2016
11
Final And Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly
On September 17, 2015, the Internal Revenue Service released final and temporary regulations under Section 871(m), the Internal Revenue Code provision that treats "dividend equivalents" paid under certain contracts as dividends from sources within the United States and therefore subject to U.S. withholding tax if paid to a non-U.S. person.
United States
29 Sep 2015
12
China's Tax Administration Issues New Rules Governing Taxation Of Offshore Indirect Transfers
Below is a brief summary and discussion of the application of Announcement 7, which applies to indirect transfers of PRC entities or properties by offshore investors.
China
24 Feb 2015
13
New UK Withholding Tax Exemption Set To Boost The UK Private Placement Market
On 4 December, George Osborne in his Autumn Statement, announced a new UK withholding tax exemption for interest payments on UK private placements.
UK
19 Dec 2014
14
MoFo Tax Talk - Volume 7, Issue 3 November 2014
We held up this issue of Tax Talk in hopes the November 4 U.S. midterm elections would clear up the political fog surrounding tax policy in Washington, D.C.
United States
21 Nov 2014
15
Tax Talk: Volume 7, No. 2 July 2014
With the halfway mark of 2014 just behind us, we are pleased to share with you in this issue of Tax Talk some of the more noteworthy tax developments from Q2.
United States
4 Aug 2014
16
MoFo Tax Talk: Volume 6, Issue 4
Before we completely close the door on 2013 and ring in 2014, this issue of Tax Talk brings you some of last quarter’s more noteworthy tax highlights and developments.
United States
4 Feb 2014
17
IRS Releases Final And New Proposed Regulations That Define "Dividend Equivalent" For U.S. Withholding Tax Purposes
On December 5, 2013, the Internal Revenue Service finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats "dividend equivalents" paid under securities lending transactions, sale-repurchase transactions and certain notional principal contracts as dividends from sources within the United States and therefore subject to U.S. withholding tax.
United States
5 Jan 2014
18
IRS Releases Draft FATCA FFI Agreement
On October 29, 2013, the Internal Revenue Service ("IRS") released Notice 2013-69 (the "Notice"), which includes a draft of the long-awaited "FFI Agreement" that a foreign financial institution ("FFI") seeking to comply with the Foreign Account Tax Compliance Act ("FATCA") must sign with the IRS.
United States
13 Nov 2013
19
FATCA Registration Begins
The Internal Revenue Service recently announced the opening of the Foreign Account Tax Compliance Act registration website.
United States
28 Aug 2013
20
MoFo New York Tax Insights, Volume 6, Issue 1 - April 2013
A discussion on the possible financial instrument tax reform in the United States.
United States
9 May 2013
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