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ITSG Global Tax Journal   May 2020 - Volume 3 No. 2

COVID-19: India Tax and Regulatory Update
By Jairaj Purandare and Shibani Bakshi Parekh (India)

India Fights COVID-19 in Matters in Addition to Tax
By Sakate Khaitan and Abbas Jaorawala (India)

Actions With Tax in Japan to Cope With COVID-19 Pandemic
By Jun Nagamine (Japan)

Singapore COVID-19 Support Measures and Tax Guidance
By Sunil Iyer (Singapore)

Highlights of the COVID-19 Tax Measures
By Daniel Ngumy and Kenneth Njuguna (Kenya)

COVID-19: Austria
By Dr. Niklas Schmidt (Austria)

State of Emergency Business Measures COVID-19
By Jivko Ivanov (Bulgaria)

Main Cyprus Measures in Response to COVID-19
By Alexis Joannides (Cyprus)

COVID-19 Pandemic Measures
By Petr Guth (Czech Republic)

Extraordinary French Tax Relief Measures For Enterprises
By Arnaud Jouanjan and Christophe Jolk (France)

COVID-19 – Tax Relief Measures
By Petra Eckl (Germany)

COVID-19 – V.A.T. Relief
By Petra Eckl (Germany)

COVID-19 – Tax Relief For In-Vestment Funds
By Petra Eckl (Germany)

New Tax Provisions Set Forth by Law Decree No. 18 of 17 March 2020
By Andrea Tavecchio and Riccardo Barone (Italy)

Luxembourg - Main Measures
By Graham J. Wilson (Luxembourg)

Coronavirus State of Emergency Measures
By Miguel Torres and João Luís Araújo (Portugal)

COVID-19 Tax Measures Russian Federation
By Grigory Nistratov (Russia)

COVID-19: Spanish Tax and Legal Measures
By Luis J. Durá (Spain)

Coronavirus Information Hub: F.A.Q.
By Stephan Neidhardt (Switzerland)

Coronavirus Information Hub: F.A.Q. - Financings/Financial Restructurings
By Theodor Hδrtsch (Switzerland)

COVID-19: Switzerland
By Aliasghar Kanani and Thierry Boitelle (Switzerland)

COVID-19: United Kingdom
By Kevin Offer and Ian Bowie (United Kingdom)

Amendments to the Taxation Regime in Argentina as a Consequence of COVID-19
By Javier Canosa (Argentina)

Tax and Customs Extraordinary Measures in Brazil - #2
By Celso Grisi, Gonçalo Falcão, Paulo Rage and Ivan Tauil (Brazil)

Chile – COVID-19 Measures
By Omar Morales (Chile)

Canada’s Financial Support During the Covid-19 Pandemic
By Peter Weissman and Matthew Cho (Canada)

U.S.: Cares Act Loans and Business Tax Provisions and I.R.S. Announce-Ments On Stranded Individuals
By Stanley C. Ruchelman and Galia Antebi (USA)

  • May 2020 - Insights Vol. 7 No. 3 (Ruchelman P.L.L.C.)
    Taxation of Real Estate Investment in Israel; U.K. Mandatory Disclosure Regime (DAC6); How Not to Borrow a Treaty: Smith v. Commr; Heads I Win, Tails You (I.R.S.) Lose – Not Anymore: Hybrid Dividends and Code §245A(e); Anti-Abuse Rules of Temp. Reg. §1.245A-5T – A New Cerberus for the U.S. Tax System; Help – My Exclusively Foreign Trust Now Has a U.S. Beneficiary! What Are the Issues a Trustee Will Now Face in 2020?; U.S.: CARES Act Loans and Business Tax Provisions and I.R.S. Announcements on Stranded Individuals; Corporate Matters: The Value of Par Value
  • March 2020 - Insights Vol. 7 No. 2 (Ruchelman P.L.L.C.)
    Swiss Corporate Tax Reform: T.R.A.F. in a Nutshell; The Netherlands Introduces Compensation Regulation to Discourage “Dormant Employment”; The Multilateral Instrument and Its Applicability in India; Foreign Tokens – U.S. Tax Characterization: Questions and Discussion; O.E.C.D. to Use Hybrid Model to Develop Digital Economy Nexus and Profit Attribution Rules; Variety Is the Spice of Life: Alternate Tax Structures for a U.S. Individual Disposing of Foreign Real Property; Transfer of Business Contracts – I.R.S. Disagrees with Greenteam, No Capital Gains Without a Fight; J-5 Step Up Anti-Money Laundering in 2020, Sights Set on Central America
  • January 2020 - Insights Vol. 7 No. 1 (Ruchelman P.L.L.C.)
    A gRett-able Situation: New Trends in German Real Estate Transfer Tax on Share Deals; Portuguese Taxation of Distributions from Trust Capital: A Critical Assessment; O.E.C.D. Unified Approach Garners Less Unified Comments from Europe’s Tech Producers and Users; Same Same, But Different: Taxation of the Sale of Stock of an Indian Company by a U.S. Person; German Supreme Tax Court Rules in Favor of Taxpayer – U.S.-German Repatriation Non-taxable
  • December 2019 - Insights Vol. 6 No. 10 - Year in Review (Ruchelman P.L.L.C.)
    IR35 – Why Are U.K. Businesses So Concerned?; New Developments on the V.A.T. Regime of Holding Companies; 2019 Welcomes New Finnish Interest Deduction Limitations; Can Tax Authorities Demand Access to Audit Workpapers? Canadian Experience Follows U.S. Rule; O.E.C.D. on Digital Business – Seriously?!; Tax Authorities Eye Gsk-Hul Merger: Could Attract Tax on Long-Term Capital Gains and Brand Transfer; Trust Regulations and Payment Services: Dutch Law in 2019; Strategies for Foreign Investment in Indian Start-Ups; Austria, France, and Italy to Introduce Digital Services Taxes; Foreign Investment an U.S. Real Estate – A F.I.R.P.T.A. Introduction; The Impact of Brexit On German Taxes for Private Clients and Nonprofit Organizations; India and the Digital Economy – The Emerging P.E. and Attribution Issues; 2020 Will Mark the End of an Era: Swiss Corporate Tax Reform Accepted; 87 Reflections on My 66 Years in Public Accounting; C.J.E.U. Judgments on Danish Beneficial Ownership Cases; Employers in the Netherlands: Prepare for Changes to Labor and Dismissal Laws in 2020; India Budget 2019-20; Israeli C.F.C. Rules Apply to Foreign Real Estate Companies Controlled by Israeli Shareholders; Collecting Another Country’s Taxes – Recent Experience in the Canada-U.S. Context
  • November 2019 - Insights Vol. 6 No. 9 (Ruchelman P.L.L.C.)
    Collecting Another Country’s Taxes – Recent Experience in the Canada-U.S. Context; How Soon Is Now? O.E.C.D. Starts Work on a Substitute for Unilateral Digital Economy Fixes; Domestic Partnerships Treated as Entities and Aggregates: New Approach for G.I.L.T.I. and Subpart F; Nonprofits: Creeping Commercialization and the Specter of Unrelated Business Income Tax; Saving Clementine: Improving the Code §163(j) Deduction; I.R.S. Releases Relief Procedures for Certain Expats While Warning Bells Ring for Others; S.A.L.T. Cap Repeal Case Dismissed; I.R.S. Placing Watchdog Agents in International Financial Centers
  • September 2019 - Insights Vol. 6 No. 8 (Ruchelman P.L.L.C.)
    India Budget 2019-20; Israeli C.F.C. Rules Apply to Foreign Real Estate Companies Controlled by Israeli Shareholders; Do You Have to Withhold 30% on Payments to a Non-U.S. Independent Contractor?; Preferred Yet Neglected — A Plea for Guidance on Redemptions of C.F.C. Preferred Stock in the Wake of U.S. Tax Reform; U.S. Tax Litigation Update — The President’s Tax Returns and the New S.A.L.T. Cap; Corporate Matters: F.I.R.R.M.A. Proposed Regulations Expand C.F.I.U.S. Oversite on Foreign Investment; U.S. Taxation of Cloud Transactions and Digital Content Transfers: 20-Year-Old Regulations Finally Move with the Times; Cryptocurrencies — Latest Developments on Either Side of the Atlantic and Beyond
  • July 2019 - Insights Vol. 6 No. 7 - Holding Companies of Europe (Ruchelman P.L.L.C.)
    Holding Companies of Europe – Tax Planning for European Expansion in a Changing Landscape
  • June 2019 - Insights Vol. 6 No. 6 (Ruchelman P.L.L.C.)
    C.J.E.U. Judgments on Danish Beneficial Ownership Cases; Employers in the Netherlands: Prepare for Changes to Labor and Dismissal Laws in 2020; The Devil in the Detail: Choosing a U.S. Business Structure Post- Tax reform; Debt Characterization and Deductibility Under Domesticated International Rules; Qualified Opportunity Zones: Second Set of Proposed Regulations Offers Greater Clarity to Investors; Is the 100% Dividend Received Deduction Under Code §245A About as Useful as a Chocolate Teapot?; Grecian Magnesite Put to Bed: Tax Court Ruling Affirmed On Appeal; Updates and Other Tidbits
  • May 2019 - Insights Vol. 6 No. 5 (Ruchelman P.L.L.C.)
    India and the Digital Economy – The Emerging P.E. and Attribution Issues; 2020 Will Mark the End of an Era: Swiss Corporate Tax Reform Accepted; Reflections on My 66 Years in Public Accounting; Proposed F.D.I.I. Regulations: Deductions, Sales, and Services; Peeling the Onion to Allocate Subpart F Income – This Will Make You Cry!; Missed Opportunities – Tax Court Shows No Mercy for Indirect Partner; Corporate Matters: Delaware Law Allows L.L.C. Divisions; New York State Renews the Three-Year Clawback for Gifts; New York State Says No to Annual Pied-ΰ-Terre Tax, Yes to Increased Real Estate Transfer Taxes
  • April 2019 - Insights Vol. 6 No. 4 (Ruchelman P.L.L.C.)
    Austria, France, and Italy to Introduce Digital Services Taxes; Foreign Investment an U.S. Real Estate – A F.I.R.P.T.A. Introduction; The Impact of Brexit On German Taxes for Private Clients and Nonprofit Organizations; Anti-Tax Arbitrage the U.S. Way; The Responsible Party – Changes Effective May 2019; State and Local Tax Credit Programs – Businesses May Get What Individuals Cannot; It’s Time for Cayman Shell Entities to Come Out of Their Shells and Show Economic Substance; New Jersey Provides G.I.L.T.I. Guidance
  • March 2019 - Insights Vol. 6 No. 3 (Ruchelman P.L.L.C.)
    Trust Regulations and Payment Services: Dutch Law in 2019; Strategies for Foreign Investment in Indian Start-Ups; F.B.A.R.’s – What You Need to Know; The I.R.S. Approach to Dependent Agent Status; More Permanent Establishments: The Dwindling Preparatory and Auxiliary Activities Exception; Democrats Turn to Tax Reform to Reduce Wealth Disparity; Who’s Got the B.E.A.T.? Special Treatment for Certain Expenses and Industries
  • February 2019 - Insights Vol. 6 No. 2 (Ruchelman P.L.L.C.)
    Can Tax Authorities Demand Access to Audit Workpapers? Canadian Experience Follows U.S. Rule; O.E.C.D. on Digital Business – Seriously?!; Tax Authorities Eye GSK-HUL Merger: Could Attract Tax on Long-Term Capital Gains and Brand Transfer; Proposed Code §864(c)(8) Regulations Codify Tax on Gain from Sale of Partnership Interest; Proposed Amendments to F.A.T.C.A. Suggest Reducing or Deferring Withholding; Who’s Got the B.E.A.T.? A Playbook for Determining Applicable Taxpayers and Payments
  • January 2019 - Insights Vol. 6 No. 1 (Ruchelman P.L.L.C.)
    New Developments on the E.U. V.A.T. Regime of Holding Companies; 2019 Welcomes New Finnish Interest Deduction Limitations; Additional Guidance on New Opportunity Zone Funds
  • December 2018 - Insights Vol. 5 No. 11 - Year in Review (Ruchelman P.L.L.C.)
    2018 Year in Review - A Year of Guest Features
  • November 2018 - Insights Vol. 5 No. 10 (Ruchelman P.L.L.C.)
    Alta Energy Affirms Treaty Benefits: A Canadian Case Study For Applying the M.L.I.; A Deep Dive Into G.I.L.T.I. Guidance; C-Corps Exempt From Full Scope of Foreign Income Inclusion; How To Handle Dual Residents: the I.R.S. View on Treaty Tie-Breaker Rules
  • October 2018 - Insights Vol. 5 No. 9 (Ruchelman P.L.L.C.)
    Dutch Corporate Tax Reform: Dividend Tax Remains, A.T.A.D. Arrives, and Tax Rates Drop; Extension of German Taxation on Foreign Companies Holding German Real Estate; Transition Tax – Proposed Regulations Are Here; Qualified Business Income – Are You Eligible For A 20% Deduction? Part II: Additional Guidance
  • September 2018 - Insights Vol. 5 No.8 (Ruchelman P.L.L.C.)
    Germany – Anti-Treaty Shopping Rule Infringes on E.U. Law; Hybrid Mismatches: Where U.S. Tax Law and A.T.A.D. Meet; Opportunity Zone Tax Benefit – How Does It Work and Can Foreign Investors Benefit?
  • August 2018 - Insights Vol. 5 No. 7 - Holding Companies of Europe (Ruchelman P.L.L.C.)
    Holding Companies of Europe - Tax Planning For European Expansion in A Changing Landscape
  • July 2018 - Insights Vol. 5 No. 6 (Ruchelman P.L.L.C.)
    Joint Audits: A New Tool To Combat Crossborder Tax Evasion; Coming To The U.S. After Tax Reform; Have You Inherited A P.F.I.C.? – What It Means To Be A U.S. Beneficiary
  • June 2018 - Insights Vol. 5 No. 5 (Ruchelman P.L.L.C.)
    O.E.C.D. And European Commission Unveil Proposals On Taxation Of The Digital Economy; Managing A Transfer Pricing Exam? Wash Your Hands With Soap And Water; The F-1 Visa – Privileged U.S. Tax Status And How To Keep It
  • May 2018 - Insights Vol. 5 No. 4 (Ruchelman P.L.L.C.)
    Failure To Prevent – The Future Of Adviser Obligations; New Tax Treaty Between France And Luxembourg: French Tax Implications For Investors; G.D.P.R. Is Imminent – Is Your U.S. Business Prepared?
  • March 2018 - Insights Vol. 5 No. 3 (Ruchelman P.L.L.C.)
    A New Definition Of Permanent Establishment In Italian Domestic Income Tax Law; India Budget 2018-19; Changes To C.F.C. Rules – More C.F.C.'s, More U.S. Shareholders, More Attribution, More Compliance; Investing In U.S. Real Estate On A (Possibly) Tax-Free Basis
  • February 2018 - Insights Vol. 5 No. 2 (Ruchelman P.L.L.C.)
    Doing Business Post-Brexit: What To Expect In The United Kingdom Qualified Business Income – Are You Eligible For A 20% Deduction? B.E.A.T.-Ing Base Erosion: U.S. Subjects Large Corporations To Anti-Abuse Tax
  • January 2018 - Insights Vol. 5 No. 1 (Ruchelman P.L.L.C.)
    Impact of The Tax Cuts And Jobs Act on U.S. Investors in Foreign Corporations; A New Tax Regime For C.F.C.'S: Who Is G.I.L.T.I.?; Modifications To The Foreign Tax Credit System Under The Tax Cuts and Jobs Act; Circular Letter No. 25/E Clarifies Italy'S New Carried Interest Regime
  • December 2017 - Insights Vol. 4 No. 12 (Ruchelman P.L.L.C.)
    2017 Year in Review – Looking Forward, Looking Back; The U.K. Trust Registration Service: Impact For Trustees; Austrian Guidance on Taxation of Bitcoin and Other Cryptocurrencies; Tax 101: Virtual Currency – What Is It? And How Is It Taxed?; A Year of Guest Features
  • November 2017 - Insights Vol. 4 No. 11 (Ruchelman P.L.L.C.)
    Brazil 2017: Tax Developments For Business Transactions; New Transparency Register in Germany; Anti-Inversion Rules Are Not Just For Mega-Mergers – Private Client Advisors Take Note; The Sharing Economy Part 2: Governments Strike Back
  • October 2017 - Insights Vol. 4 No. 10 (Ruchelman P.L.L.C.)
    An American In London: Due Diligence Observations; Double Dutch: Dividend Tax Reform Extends Exemption, Yet Tackles Abuse; The Changing Face Of Service Permanent Establishments; Swiss Federal Council Opens Consultation Process On Tax Proposal 17
  • September 2017 - Insights Vol. 4 No. 9 (Ruchelman P.L.L.C.)
    Spontaneous Exchange Of Tax Rulings – The Swiss Angle; Tax Roulette: Buying A Business Jet In; 2017 – Why Following The Patriot's; Example May Lead To A Jackpot; A Case Of Nonacquiescence: I.R.S. Opposes Bartell Decision; Legal And Practical Strategies For Managing Tax Disputes In India
  • August 2017 - Insights Vol. 4 No. 8 (Ruchelman P.L.L.C.)
    Caveat Dominus: A Comparison Of Post-Employment Entitlements In The U.S. And Italy When Executive Employment Is Terminated Without Cause; When The (Fake) I.R.S. Calls – Memoirs Of The Tax Phishing World; Foreign Partner Not Subject To U.S. Tax; On Gain From Redemption Of U.S. Partnership Interest
  • July 2017 - Insights Special Editions (Ruchelman P.L.L.C.)
    Outbound Acquisitions: Holding Companies Of Europe – A Guide For Tax Planning, Or A Road Map For Difficulty?
  • July 2017 - Taxation of Canadian residential real estate: what non-residents need to know (Cadesky Tax)
    This article provides a quick summary of important points concerning the taxation of Canadian residential real estate for non-residents of Canada.
  • June 2017 - Insights Vol. 4 No. 6 (Ruchelman P.L.L.C.)
    High-Speed Tax Reform: The U.K. Diverted Profits Tax & Restrictions On Corporate Interest Deductions; Qualified Small Business Stock & The Eb-5 Visa Program – An Attractive Combination For Potential Investors; Sale Of A Partnership Interest By A Foreign Partner – Is Rev. Rul. 91-32 Based On Actual Law Or Administrative Wishes?; I.R.S. Breaks The Silence With Rev. Rul.2017-09, Issues Guidance On "North-South"Transactions;
  • May 2017 - Insights Vol. 4 No. 5 (Ruchelman P.L.L.C.)
    Economic Nexus Through Ownership And Use Of Intellectual Property; I.R.S. Information Exchanges & The Coordinated Tax Raids On Credit Suisse; Amazon Makes The C.U.T. – An Important Taxpayer Win, A Reminder To Consider Transactional Evidence; Tax 101: Taxation Of Intellectual Property – The Basics; Foreign Tax Credit May Not Be Available For Gains Derived Outside The U.S.
  • April 2017 - Insights Vol. 4 No. 4 (Ruchelman P.L.L.C.)
    U.K. Drops Changes To Non-Domicile Regime, But Likely Not For Long; Value-Added Tax 101 – A Far Cry From A Border Tax; Cross-Border Complexities: What You Need To Know Before Your Non-U.S. Client Invests In The U.S.; Valuation – More Art Than Science
  • March 2017 - Insights Vol. 4 No. 3 (Ruchelman P.L.L.C.)
    Pre-Immigration Planning: Drop-Off Trusts + Private Placement Life Insurance – If The Tools Fit, Use Them; A Look At The House G.O.P.'S; "Destination-Based Cash Flow With Border Adjustment"; India Budget 2017-18; New Developments In The World Of Reverse Like-Kind Exchanges
  • February 2017 - Insights Vol. 4 No. 2 (Ruchelman P.L.L.C.)
    Swiss Corporate Tax Reform Postponed; Italy Introduces A 15-Year Preferential Tax Regime For Wealthy Individuals Taking Up Tax Residence In Italy; Proposed Directive On The E.U. Common (Consolidated) Corporate Tax Base - A Primer; India – Guidelines Issued For Determining Place Of Effective Management
  • January 2017 - Insights Vol. 4 No. 1 (Ruchelman P.L.L.C.)
    U.K. Criminal Penalties For Improper Tax Planning – Could You Be Effected?; News On The French Front: Tax Law Changes For Corporations And Individuals; Income Taxation Of Trusts In Belgium; Trump And The Republican-Led Congress Seek Overhaul Of International Tax Rules
  • November 2016 - Insights Vol. 3 No. 10 (Ruchelman P.L.L.C.)
    European Commission Rocking The Boat; At Arm's Length; Goods And Services Tax: A Game Changer; §385 Regulations Adopted With Helpful Changes, But Significant Impact Remains; French V. U.S. Share-Based Compensation Plans: A Comparative Anaysis
  • October 2016 - Insights Vol. 3 No. 9 (Ruchelman P.L.L.C.)
    Spanish Tax Implications Of Nonresident Private Investment In Spanish Real Estate; Global Exchange Of Information: How Does The U.S. Fit Into The Puzzle?; Meet The U.S. Foreign Trust; European State Aid And W.T.O. Subsidies
  • September 2016 - Insights Vol. 3 No. 8 (Ruchelman P.L.L.C.)
    Further Developments For U.K. Non-Dom Individuals; Treasury Attacks European Commission On State Aid – What Next?; Usufruct, Bare Ownership, & U.S. Estate Tax: An Unlucky Trio; Projected Tax Expense – Can It Be Computed On The Back Of Envelope?
  • July / August 2016 - Insights Vol. 3 No. 7 (Ruchelman P.L.L.C.)
    European Registration & French Tax Law Create Pitfalls For U.S. Truststax 101: Foreign Settlors, U.S. Domestic Trusts, And U.S. Taxationcrowdfunding: A Popular Way To Invest, But Watch Out For Taxesa New Way To Do The Splits: B.E.P.S. Guidance Falls Short Of Enabling Global Formulary Apportionmentand More
  • June 2016 - Insights Vol. 3 No. 6 (Ruchelman P.L.L.C.)
    The End Of The Negotiation: Protocol To India-Mauritius Tax Treaty Finally Released; French Life Insurance Policies: A U.S. Income Tax Perspective; E.U. State Aid – The Saga Continues
  • May 2016 - Insights Vol. 3 No. 5 (Ruchelman P.L.L.C.)
    Canada Adopts Changes To Trust & Estate Taxation Rules; Italy Modernizes Tax Treatment Of L.B.O. Transactions; U.S. On The Blacklist – Is Delaware A Tax Haven?; Inbound §332 Liquidations & Inbound Asset Reorganizations
  • April 2016 - Insights Vol. 3 No. 4 (Ruchelman P.L.L.C.)
    U.K. Adopts Public Register Of People With Significant Control Over U.K. Corporations; Inversions Under Siege: New Treasury Regulations Issued; Country-By-Country Reporting – Where Are We Going?; Transfer Pricing Positions Of Consolidated Groups: After Guidant
  • March 17, 2016 - Investment Insight on SEZs (Bangkok Global Law)
  • March 17, 2016 - Investment Insight on Cluster and Supercluster (Bangkok Global Law)
  • March 17, 2016 - Investment Insight on 10 targeted industries (Bangkok Global Law)
  • March 17, 2016 - Investment Insight on Investment Acceleration (Bangkok Global Law)
  • March 17, 2016 - Investment Insight on Local Investment Promotion (Bangkok Global Law)
  • March 17, 2016 - Investment Insight on Future Industries (Bangkok Global Law)
  • March 2016 - Insights Vol. 3 No. 3 (Ruchelman P.L.L.C.)
    India Budget 2016-17; Exchange Of Information: Israel Inches; Toward International Norms; U.S. Treasury Announces New U.S. Model; Income Tax Convention; Corporate Matters: Anatomy Of A Limited; Liability Company Agreement – Part I
  • February 29, 2016 - Key highlights of India Budget 2016-17 (JMP Advisors)
  • February 2016 - Insights Vol. 3 No. 2 (Ruchelman P.L.L.C.)
    B.E.P.S. Initiative Spawns Unfavorable Permanent Establishment Court Decisions; Apple In Europe – The Uphill Battle Continues; Partnership Tax Traps And Recent Guidance; A Concise Guide To Acquisition Vehicles For The Purchase Of U.S. Real Estate By Foreign Individuals
  • January 2016 - Insights Vol. 3 No. 1 (Ruchelman P.L.L.C.)
    The Common Reporting Standard – A Global F.A.T.C.A?; Taxpayers Take Note: I.R.S. Publishes Audit Guides For International Examiners; P.A.T.H. Act Leads To Widespread Changes; I.R.S. Adopts O.E.C.D. Standard In New Cbcreporting Regulations
  • December 2015 - Insights Vol. 2 No. 10 (Ruchelman P.L.L.C.)
    A Guide To Non-Dom Taxation; Tax 101: How To Structure A Corporate Division; Anti-Inversion Rules Expanded; Congree Enacts Sweeping New Partnership Audit Rules
  • October / November 2015 - Insights Vol. 2 No. 9 (Ruchelman P.L.L.C.)
    A Proposed Treatment For H.T.V.I.; President's Legislative Proposals; An Englishman In New York - Tax Considerations For Foreign Individuals; Russian Recovery Fund V. U.S.
  • September 2015 - Insights Vol. 2 No. 8 (Ruchelman P.L.L.C.)
    The Past, Present, And Future Of Luxembourg Special Purpose Companies; Inadequate Gift Description – I.R.S. Tries For A Second Bite At The Apple; Final Stages Of B.E.P.S. Implementationand Its Effects; Corporate Matters: Are You Doingbusiness In New York?
  • August 2015 - Insights Vol. 2 No. 7 (Ruchelman P.L.L.C.)
    The (Non) Recognition Of Trusts In Germany; Tax Court Strikes Down I.R.S. Position On Stock-Based Compensation In Altera Case; U.S. Taxation Of Carried Interest; Busy Month For B.E.P.S.
  • June / July 2015 - Insights Vol. 2 No. 6 (Ruchelman P.L.L.C.)
    2015 Summer Budget Announced In U.K.; Tax Rulings In The European Union - State Aid As The European Commission's Sword Leading To Transparency On Rulings; Legislation To Relax F.I.R.P.T.A. Gets Bipartisan Support; U.S. Taxation Of Carried Interest; Can B.E.P.S. Survive Without U.S. Support?
  • May 2015 - Insights Vol. 2 No. 5 (Ruchelman P.L.L.C.)
    Transfer Pricing Implications Of The B.E.P.S. Action Plan; "Trust" – A New Concept In Russia; Upcoming Regulations Could Limit A; Foreign Taxpayer's Refund Or Credit; U.K. Implements 25% "Google Tax" On; Diverted Profits
  • April 2015 - Insights Vol. 2 No. 4 (Ruchelman P.L.L.C.)
    The Italian Voluntary Disclosure; J.C.T. Report On Competitiveness – A Step; Toward Consideration Of New Rules; Corporate Matters: Help – My Delaware Entity Has Been Cancelled!; Pre- Immigration Income Tax Planning,; Part Ii: Covered Expatriates
  • March 2015 - Insights Vol. 2 No. 3 (Ruchelman P.L.L.C.)
    India Announces Ambitious Budget; For 2015-16; Debt Vs. Equity: Comparing Hp Appeal; Arguments To The Pepsico Case; Falciani: "The Man Who Makes The Rich; Tremble"; Mcdonald's Accused Of Re-Routing; Royalty Payments To Avoid Billions In; European Taxes; Using A §897(I) Non-Discrimination; Election To Avoid F.I.R.P.T.A.
  • February 2015 - Insights Vol. 2 No. 2 (Ruchelman P.L.L.C.)
    Deoffshorization In Russia: C.F.C. Legislation Comes Into Effect; The Future Of Ireland As A Place To; Carry On Business In Light Of Recent; E.U. & O.E.C.D. Initiatives; U.S. Residency Certification: Pitfalls & Considerations; Tax 101: Understanding U.S. Taxation; Of Foreign Investment In Real; Property – Part Iii
  • January 2015 - Insights Vol. 2 No. 1 (Ruchelman P.L.L.C.)
    The Proposed United Kingdom "Diverted Profits Tax"; Tax 101: Understanding U.S. Taxation Of Foreign Investment In Real Property – Part Ii; 2014 Tax Extenders Legislation Finally Approved; B.E.P.S. Update; Corporate Matters: Is Your Deal Safe?
  • December 2014 - Insights Vol. 1 No. 11 (Ruchelman P.L.L.C.)
    Canadian Immigration Trust Exemption Withdrawn; Voluntary Tax Regularization: A U.S. And French Comparison; Foreign Correspondence: Notes From Abroad; Corporate Matters: Don'T Be Late – Time Is Of The Essence; Non-Willful Relief Expanded For Non-Filing Of Gain Recognition Agreement; A Bad Month For Luxembourg
  • November 2014 - Insights Vol. 1 No. 10 (Ruchelman P.L.L.C.)
    Anti-Deferral Regimes: U.S. Taxation Of Foreign Corporations; Administrative Attack On Inversions; Tax 101: Understanding U.S. Taxation Of F.I.R.P.T.A. – Part I; Marks And Spencer: The End Of An Era?
  • October 2014 - Insights Vol. 1 No. 9 (Ruchelman P.L.L.C.)
    Israeli Law Confronts International Tax Treaties And Principles Via New Treatment Of Mixed-Beneficiary Trusts; B.E.P.S.
  • September 2014 - Insights Vol. 1 No. 8 (Ruchelman P.L.L.C.)
    Inbound Investment In German Real Estate; Tax 101: Updates To Procedures Relating To Withholding Foreign Partnership Or Trust Agreements As A Result Of F.A.T.C.A.; Current Tax Court Litigation Illustrates Intangible Property Transfer Pricing And Valuation Issues; Corporate Inversion Transactions: Tax Planning As Treason Or A Case For Reform?; Corporate Matters: Delaware Or New York L.L.C.?
  • August 2014 - Insights Vol. 1 No. 7 (Ruchelman P.L.L.C.)
    The Mckesson Transfer Pricing Case; U.S.-Based Pushback On B.E.P.S.; Tax 101: Tax Planning And Compliance For Foreign Businesses With U.S. Activity; Corporate Matters: Convertible Note Financing; F.A.T.C.A. 24/7
  • July 2014 - Insights Vol. 1 No. 6 (Ruchelman P.L.L.C.)
    Using The U.K. As A Holding Company Jurisdiction: Opportunities And Challenges; I.R.S. Announces Major Changes To Amnesty Programs; Tax 101: Outbound Acquisitions – Holding Company Structures; First Circuit Holds Corporation's Possessions Tax Credit Was Not Reduced; Corporate Matters: Professional Limited Liability Companies And Professional Corporations
  • June 2014 - Insights Vol. 1 No. 5 (Ruchelman P.L.L.C.)
    Expatriation The Transatlantic Way: Overview Of The French And The U.S. Regimes; F.B.A.R. Update: What You Need To Know; Tax 101: Taxation Of Foreign Trusts; F.A.T.C.A. 24/7; O.V.D.P. Update
  • May 2014 - Insights Vol. 1 No. 4 (Ruchelman P.L.L.C.)
    Swiss Trustees And Board Members Of Foundations Have To Prepare For F.A.T.C.A.; Tax 101: Transactions In Fx: A Primer For Individuals; Proposed Partnership Regulations Will Affect Partnership Deal Economics; Corporate Matters: Angel Investing: An Introduction; F.A.T.C.A. 24/7; New York Enacts Major Corporate Taxation Reforms
  • April 2014 - Insights Vol. 1 No. 3 (Ruchelman P.L.L.C.)
    O.E.C.D. Discussion Drafts Issued Regarding B.E.P.S. Action 2 – Neutralizing The Effects Of Hybrid Mismatch Arrangements; The O.E.C.D.'s Approach To B.E.P.S. Concerns Raised By The Digital Economy; What Must Foreign Trusts And Family Corporations Do About F.A.T.C.A.?; Transfer Pricing – Bankruptcy Court Prevents I.R.S. From Pursuing Unsupported Transfer Pricing Claims; Corporate Matters: Shareholder Agreements
  • March 2014 - Insights Vol. 1 No. 2 (Ruchelman P.L.L.C.)
    I.R.S. Vs. O.E.C.D. – How Are Tax Authorities Planning To Conduct Your Next Transfer Pricing Audit; The O.E.C.D. Announces Global Standard For Automatic Exchange Of Information; F.A.T.C.A. And Trusts: A Primer; The I.R.S. Extends The Time For Estate Tax Portability Election For Small Estates; Corporate Matters: Incorporation Basics
  • February 2014 - Insights Vol. 1 No. 1 (Ruchelman P.L.L.C.)
    Year-End Review: Net Investment Income Tax; Year-End Review: F.A.T.C.A.; Year-End Review: I.R.S. O.V.D.P.; Non-Resident Alien Interest; Reporting Rules Upheld; I.R.S. Issues Regulations Regarding P.F.I.C. Reporting Requirements
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