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Interest-free loan was an indirect transfer of profits
  • Baker & McKenzie
  • France, OECD
  • May 26 2016

Transfer pricing rules apply to internal dealings between a French branch and its foreign head office. A French branch recorded in its accounts

New York City Tribunal Rejects City’s Attempt to Forcibly Combine Bank and Its Mortgage Subsidiary
  • Morrison & Foerster LLP
  • USA
  • May 26 2016

The New York City Tax Appeals Tribunal, affirming a determination of an Administrative Law Judge, has held that Astoria Bank, which engaged in a

UK Economic Crime Group: Mid-year Roundup in Economic Crime
  • Arnold & Porter LLP
  • United Kingdom
  • May 25 2016

Sweett Group Plc was sentenced on 19 February 2016 and ordered to pay £2.25 million following its conviction after an SFO investigation into its

Accessing Records With Bank of Nova Scotia Summonses
  • Morvillo Abramowitz Grand Iason & Anello PC
  • USA
  • May 20 2016

In a recent interview for this column,Caroline D. Ciraolo, the Acting Assistant Attorney General for the Tax Division of the Department of Justice

Conducting Business in Ukraine 2016
  • Baker & McKenzie
  • Ukraine
  • May 11 2016

Ukraine is located in the best part of Europe and covers a land area of 603,700 sq. Kilometers with a coastline of 2,782 kilometers, making it the

Tribunal Overturns ALJ and Holds That Bank Must Apply NOLs in Year Taxed on Non-Income Base
  • Morrison & Foerster LLP
  • USA
  • May 4 2016

The New York State Tax Appeals Tribunal has held that a taxpayer was required to use its net operating loss (“NOL”) carryforward deduction to

EU Political Update: 02 - 06 May 2016
  • Clifford Chance LLP
  • European Union, USA
  • May 2 2016

On 26 April 2016, MEPs from the Economic and Monetary Affairs Committee approved a report which outlines the European Parliament's recommendations on

Cayman Islands Quarterly Update - April 2016
  • Carey Olsen
  • Cayman Islands, OECD, United Kingdom
  • April 29 2016

The Cayman Islands and the UK have signed a framework agreement on the sharing of beneficial ownership information, which does not involve the use of

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity
  • Orrick, Herrington & Sutcliffe LLP
  • April 28 2016

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity On April 4, 2016, the IRS and U.S. Treasury Department issued

Trade Alert - April 2016, Issue 28 - Ukraine
  • Cadwalader Wickersham & Taft LLP
  • Iceland, Ukraine, USA
  • April 28 2016

Ukraine is seeking to strengthen its ties with the EU, its largest trading partner. Ukraine’s main exports to the EU are raw materials, including iron