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...

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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...

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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...

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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...

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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...

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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...

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By Carson G. Burnham (Boston) |Ogletree Deakins Ogletree Deakins’ International Practice Group is pleased to announce the inaugural issue of its international newsletter, the International Employment Update. Roger James, a partner in Ogletree Deakins’ London office, spearheaded this important and timely project, which is aimed at human resources professionals and in-house employment counsel operating on an international basis. The International Employment Update, which will be published twice yearly, includes 59 articles covering labor and employment news and developments from 50 countries. The...

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By ACG As one of the most innovate recruiting firms throughout the United States, ACG Resources is always looking for ways to improve our recruiting practices and service capabilities. Towards this end, we are pleased to announce our partnership with the Future Manager Alliance. What is FMA? Future Manager Alliance (FMA) is global outreach entity, consisting of select recruitment companies from all over the world. As the US partner, we now have the ability to develop Bilateral and multilateral services, expanding to...

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By DLA Piper Insights This month we look at the Lancashire case, where Mr Justice Fraser dispels a myth about procurement law, and raises new issues which might be thrown into the balance whilst deciding whether or not to lift the automatic stay.  We also look at the Arpacal case which confirms the law on collusion in the context of a procurement for insurance services. The EU Commission’s “notice to stakeholders” (see below) makes the point starkly that, if no...

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