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Rare taxpayer debt-equity win

Alston & Bird LLP
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Netherlands, USA
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November 28 2012

Pepsico, Inc., and Pepsico Puerto Rico, Inc. v. Commissioner, T.C. Memo 2012-269, ruled that the U.S. holder of an ambiguous security issued by its foreign affiliate did not have to treat the periodic payments received as interest, even though the affiliate was deducting interest paid under Dutch tax law

International regulatory update 17-21 September 2012

Clifford Chance LLP
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Australia, China, European Union, Global, Netherlands, Thailand, United Kingdom, USA
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September 24 2012

Clifford Chance’s International Regulatory Update is a weekly digest of significantregulatory developments, drawing on our daily content from our Alerter: Finance Industry service

U.S.Netherlands Competent Authority agreement covering limited fund mutual accounts

Alston & Bird LLP
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Netherlands, USA
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June 15 2012

In late May 2012, the Competent Authorities of the United States and the Netherlands entered into an agreement to clarify application of the United States-Netherlands income tax treaty (the “Treaty”) with respect to U.S. source dividends and interest paid to a limited fund for mutual account (LFMA

Mutual agreement between the US and the Netherlands published granting tax certainty for funds and investors

Stibbe
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Netherlands, USA
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June 11 2012

On 8 June 2012 the Dutch government published a mutual agreement between the competent authorities of the US and the Netherlands (the "MA"

The Netherlands to join joint FATCA statement

De Brauw Blackstone Westbroek
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Netherlands, USA
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April 26 2012

The US Foreign Account Tax Compliance Act ("FATCA") will come into force on 1 July 2013

Recent developments for the fourth quarter 2011

Baker & McKenzie
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Canada, China, Denmark, European Union, France, Germany, Ireland, Italy, Japan, Netherlands, Switzerland, United Kingdom, USA
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March 15 2012

The end of the year and beginning of a new year is always a busy time for us, as it is for most of our clients

Application 30-ruling on after-acquired assets

Greenberg Traurig LLP
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Netherlands, USA
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June 30 2011

When workers from abroad are assigned to the Netherlands, and they meet certain qualifications, they may be eligible for the 30-ruling

Maximizing your Dutch limited partnership legal and tax structure

Greenberg Traurig LLP
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Netherlands, USA
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March 5 2010

The Dutch limited partnership (commanditaire vennootschap or "Limited Partnership") is an efficient fund vehicle for both Dutch and non-Dutch tax-exempt investors

Search results

Rare taxpayer debt-equity win

International regulatory update 17-21 September 2012

U.S.Netherlands Competent Authority agreement covering limited fund mutual accounts

Mutual agreement between the US and the Netherlands published granting tax certainty for funds and investors

The Netherlands to join joint FATCA statement

Recent developments for the fourth quarter 2011

Application 30-ruling on after-acquired assets

Maximizing your Dutch limited partnership legal and tax structure

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