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ITSG Global Tax Journal   February 2020 - Volume 3 No. 1

When e-Sports Meet U.K. Tax: Domestic and International Considerations
By Gary Ashford (United Kingdom)

The Ultimate Beneficial Owner Register and the Netherlands
By John Graham (Netherlands)

China Eases Requirements for Claiming Treaty Benefits
By Yang Sun and Xiuning Hao (China)

Global Mobility from a U.S. Perspective: How and When Foreign Parents with U.S. Children and U.S. Assets Are Taxed
By Stanley C. Ruchelman (USA)

  • 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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