On 12 July 2019, the Dutch government published a legislative proposal implementing the Mandatory Disclosure Directive (Directive). The legislative proposal introduces mandatory disclosure rules based on which qualifying intermediaries and – under certain circumstances – taxpayers need to report certain arrangements to the relevant tax authorities. These arrangements concern potentially aggressive tax planning arrangements with a cross-border dimension and arrangements designed to circumvent reporting requirements like the Common Reporting Standard and Ultimate Beneficial Owner reporting. Implementation of the legislative proposal...

Read more

By Alan Winston Granwell,  William M. Sharp,  Robert G. Lorndale,  Christopher Fiore Marotta | Holland & Knight In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S. persons owning stock of foreign corporations through domestic partnerships. The New Guidance will impact planning and 2018 compliance/reporting decisions. For domestic partnerships and limited liability companies (LLCs) with minority U.S. partners, including private equity...

Read more

Tradewind has closed a $2.5 million trade finance facility for a company based in China and the USA that sells sustainable, ecologically sourced and manufactured homewares. The company exports to major retailers in the US including Amazon, Target, Kroger, and the Container Store as well as to distributors in key international markets globally. It is using the accelerated cash flow for working capital to increase production volumes, expand into new distribution channels, and initiate diversified brand marketing. Selling to Tier...

Read more