Change to Oregon “Tax Haven” Law
By Eric J. Kodesch, Stoel Rives LLP
In 2013, Oregon adopted a law that expanded the so-called “water’s-edge limitation” for a consolidated tax return to include corporations organized in certain listed jurisdictions (generally, countries perceived to be tax havens). Or Laws 2015, chapter 755 (SB 61) deletes the requirement to take the apportionment factors of the listed jurisdiction company into account; adds a provision stating that nothing precludes a taxpayer or the Department from asserting that a modified apportionment method is necessary to equitably apportion the taxpayer’s income, pursuant to ORS 314.667; and modifies the list of jurisdictions by replacing a reference to the former Netherlands Antilles—which ceased to exist in 2010—with the names of former constituent islands Bonaire, Curaçao, Saba, Sint Eustatius, and Sint Maarten, adding Trinidad and Tobago and Guatemala, and deleting Monaco. The bill for this law, as well as the amendment removing the apportionment relief, originated in the Oregon Senate. Accordingly, if the new law raises revenue, it may violate the Origination Clause of the Oregon Constitution (which requires bills raising revenues to originate in the House). These changes apply to tax years beginning on or after January 1, 2016.
International Law Newsletter, Fall 2011
In this issue:
From the Chair
New ICC Rules Effective January 1, 2012
Foreigners to Participate Under New PRC Social Insurance Law
Upcoming International Events
CALL FOR INTERNATIONAL LAW ARTICLES!
The International Law Section (ILS) of the Oregon State Bar is in the process of putting together a newsletter for our membership. The newsletter will include brief articles, case summaries, and news of interest to ILS members.
If you are interested in having your article, case summary, news brief, or other internationally-oriented content published in the newsletter, please email us .
We look forward to hearing from you!
Materials from June 28, 2010 CLE
Oregon State Bar International Law Section
GLOBAL WORKPLACE: Employment and Immigration Tips and Traps
3:30 PM – 5:30 PM – University of Oregon White Stag Building in Portland
Light refreshments to be provided
Click here for meeting handout.
Materials from November 9, 2009 CLE
Oregon State Bar International Law Section
From the Inside and Out: Federal and Foreign Tax Considerations in Cross-Border Transactions
Meeting Handouts
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Doing Business in China
Jon Brian Davis -
New Contract Manufacturing Regulations Present Planning Opportunities
Todd M. Beutler
Speaker Resumes
Materials from June 29, 2009 CLE
Oregon State Bar International Law Section
AT HOME AND ABROAD: DIVERSE CULTURES AND THE BUSINESS OF LAW
Meeting Handouts
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Cultural Issues in International Business Transactions
M. Christie Helmer & Paul Taylor -
Building Diversity Into Your Practice
Frank Garcia, Jr. & Lisa Lesage -
Cultural Competency – Is There an Ethical Duty?
Sylvia Stevens
Speaker Resumes
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Dagmar Butte, Moderator
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Materials from October 29, 2008 CLE
Oregon State Bar International Law Section
A PRIMER IN INTERNATIONAL ALTERNATIVE DISPUTE RESOLUTION
Presentation by
Zela G. Claiborne, Esq., and Steven C. Smith, Esq.
October 29, 2008
Index of Materials
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“Designing a Fair, Efficient and Cost-Effective Arbitrationâ€
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London Court of International Arbitration (LCIA)
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American Arbitration Association International Dispute Resolution Procedures
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JAMS
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International Bar Association
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United Nations Materials
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Oregon International Commercial Arbitration and Conciliation Act
- May, 2007 – International Joint Ventures: A Practicum. By Paul Ehrlich and Milton R. Stewart
- April, 2006 – Recent Changes in China’s Laws Provide Greater Access for Foreign Businesses. By Akana K.J. Ma
- February, 2006 – In re Parmalat Securities Litigation – The Dawn of “One Firm†International Accounting Liability. By Lew E. Delo
- May, 2005 – New York Common Law Copyright Infringement and the International Copyright Public Domain. By Jacob J. Carroll
- March, 2005 – Importers’ Compliance with U.S. Laws – When a Dusting of Flour Could Save Your Business. By Akana K.J. Ma
- March, 2005 – What Is It? And Where Is It Going? The U.S. Government Wants to Know – U.S. Exports and Encryption. By Akana K.J. Ma
- January, 2005 – International Commercial Arbitration: A Few Things Every Business Executive & Lawyer Should Know. By Steven Charles Smith, Jur. Dr., FCIArb.