By AEM Carnelutti  The Filmspeler case On 26 April 2017, the European Court of Justice (“CJEU”) rendered its decision in case C-527/15, Stichting Brein v Wullems t/a Filmspeler. CJEU was requested to establish whether it constitutes a communication to the public with the sale of a product (a multimedia player named ‘Filmspeler’) in which the seller installed certain add-ons hyperlinking to websites on which copyright-protected works were made directly available to the public without the prior authorization of the rights holder. The CJEU held...

Read more

By Royal DSM Royal DSM, a global science-based company active in health, nutrition and materials, has repurchased 136,650 of its own shares in the period from 19 March 2018 up to and including 22 March 2018 at an average price of €80.59. This is in accordance with the repurchase, covering commitments under share based compensation plans and for stock dividends, announced on 19 March 2018. The consideration of this repurchase was €11.0 million. For more detailed information see the ‘Daily transaction details 1.6m Share Repurchase Program...

Read more

By Frances Rayer | frayercozen.com | Cozen O'Connor USCIS announced on March 20, 2018, that it will temporarily suspend premium processing for all FY2019 H-1B cap-subject petitions, including petitions seeking an exemption for individuals with a U.S. master’s degree or higher. The suspension is expected to last until September 2, 2018. Any Form I-907 Request for Premium Processing filed with a cap-subject H-1B petition will be rejected. NOTE: This temporary suspension of premium processing only affects H-1B cap-subject petitions. USCIS will continue to...

Read more

By DLA PIPER Insights The IRS recently announced that it will end the 2014 Offshore Voluntary Disclosure Program (2014 OVDP) on September 28, 2018.  The 2014 OVDP is the most recent iteration of the IRS’s offshore voluntary disclosure programs that were first announced in 2009.  Taxpayers with unreported (closed or existing) bank accounts or foreign financial assets should contact tax counsel as soon as possible to discuss options for coming into compliance.  The IRS cites the significant decline in the number of taxpayers participating...

Read more

By Illya Sverdlov and Dmytro Rylovnikov | DLA PIPER On 7 March 2018 the Cabinet of Ministers Resolution No.108 as of 31 January 2018 (Resolution) entered into force. The Resolution updates the List of countries which qualify for criteria envisaged by para 39.2.1.2 of the Tax Code (List), in particular by the exclusion of some countries. A country's presence on the List means that transactions with companies which are registered in or are tax residents in such countries: may be qualified...

Read more

By Loyens & Loeff On 20 March 2018, France and Luxembourg signed a new double tax treaty (the “Treaty”) based on the latest version of the OECD model convention and implementing BEPS minimum standards. The Treaty will facilitate various types of investments in France through Luxembourg funds; changes to taxation of certain real estate investment vehicles may, however, have an impact on some existing structures and require a restructuring. The Treaty reduces the minimum shareholding threshold to 5% (with a minimum...

Read more

By BDO United States The $1.5 trillion new tax law represents the most sweeping change to tax code in a generation. Tax reform of this magnitude will have broad implications for government contractors. While accountants and tax departments wade through the 185-page legislation, here are the top 10 things government contractors need to know: 1. The corporate tax rate was permanently reduced from 35 percent to 21 percent. The top corporate tax rate has been permanently reduced from 35 percent to a flat rate of...

Read more

By Andrew C. Collins | Managing Partner | Bannockburn Global Forex, LLC   I am beginning this currency update email at 11:18 am EDT.  I note this because it is my intent not to send it until later this afternoon, probably 3:30 pm.  The purpose of this time delay is to highlight the differences between my thoughts on the market now versus how they might change – in real time – this afternoon after the FOMC meeting.   As of now (11:21 am) the...

Read more

By Loyens & Loeff On 21 March 2018, the European Commission (EUCommission) proposed two Council Directives addressing the taxation of the digital economy. The introduction of a digital services tax (DST) on revenues from certain digital services, as an interim solution, should affect about 100 large companies, mostly U.S.-based. The corporate taxation of a significant digital presence (Digital PE) would be the comprehensive long-term solution and could have an impact on companies across a wider range of economic sectors, such...

Read more