Rahman Ravelli Solicitors
Nicola Sharp of financial crime specialists Rahman Ravelli summarises the case.
Alston & Bird
Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles.
Moodys Private Client Law LLP
The cost of being a US citizen living abroad extends well beyond going through the motions of staying US tax compliant annually. It includes legal/accounting fees, huge failure-to-file penalties if late...
Caplin & Drysdale
The Internal Revenue Service (IRS) has placed certain Malta-based pension plan arrangements on its annual "Dirty Dozen" list of "tax scams."
Winston & Strawn LLP
One tax-efficient way for a non-United States person to invest in U.S.-based loan activities is to rely on the provisions of an applicable U.S. income tax treaty which allows the lending business income...
Holland & Knight
•The United Kingdom and the U.S. Competent Authorities have entered into a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty)
Many taxpayers are familiar with information document requests where taxpayers are notified that taxing authorities are inquiring into certain transactions based on their receipt of the request.
Groom Law Group
The U.S. has issued an announcement with guidance on how the 2009 amendment to the tax treaty between the U.S. and Switzerland applies to pension and retirement arrangements of both countries.
For U.S. tax purposes, gain or loss upon a sale or exchange of property is generally sourced based on the tax home of the seller. For a foreign person investing in a partnership...
On June 5, 2021, the Finance Ministers and Central Bank Governors of the G7 countries issued a Communiqué announcing their agreement on the conceptual framework for a substantial revision...
Amount B aims to standardize the remuneration of related party distributors that perform baseline marketing and distribution activities in a manner that is aligned with the arm's length principle.
Cadwalader, Wickersham & Taft LLP
This tax would be reinforced by rules affecting payments between related parties and by denying certain treaty benefits.
The Mutual Agreement Procedure ("MAP") is a useful dispute resolution mechanism for multinational companies facing a transfer pricing...
In Through the Looking-Glass, by Lewis Carroll, Humpty Dumpty makes the following point when speaking to Alice
The nexus rules are designed to protect the interests of smaller jurisdictions, and in particular developing economies, and their desire to benefit from the new taxing right.
Akin Gump Strauss Hauer & Feld LLP
During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial
Holland & Knight
Expatriation has increased significantly in 2020. The latest U.S. Department of the Treasury Report reflects that a record 6,047 individuals expatriated during the first three quarters of 2020.
Ostrow Reisin Berk & Abrams
The COVID-19 pandemic has resulted in financial losses for many businesses, including manufacturers.
On October 8, 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) announced that 136 countries have agreed on a two-pillar framework that would dramatically alter the taxation of multinational enterprises (MNEs).
Ropes & Gray LLP
Tax partner Kat Gregor and tax counsel Elizabeth Julia Smith published a chapter in the International Comparative Legal Guide – Corporate Tax 2021 entitled...