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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)

  • NEW
    September, 2021 - Tax Matters Issue No. 2021/09 (JMP Advisors)
    The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during August 2021.
  • August 11, 2021 - Tax Matters Issue No. 2021/08.2 (JMP Advisors)
    In this edition, we have discussed case laws on some interesting issues such as advance given to the managing director in return for providing collateral security and personal guarantee towards loan taken by private limited company not taxable as deemed dividend.
  • August 2021 - Tax Matters Issue No. 2021/08 (JMP Advisors)
    The TLA 2021 proposes to dilute the impact of the retrospective amendments that were brought about by the Finance Act, 2012 which effectively made indirect transfer of assets located in India taxable in India retrospectively with effect from Financial Year 1961-62.
  • July 2021 - Tax Matters Issue No. 2021/07 (JMP Advisors)
    In this edition, we have discussed rulings which cover some interesting issues on set-off of brought forward business loss of earlier years against capital gain income; assessment order passed under section 143(3A) of the Income-tax Act, 1961 after 31 March 2021 is bad in law; income from Indian Depository Receipts is exempt under Article 22 of India- Mauritius DTAA; write-off of investment in loss making overseas subsidiaries is allowed as business loss; question of beneficial DTAA rate over Dividend Distribution Tax rate; sum received from holding company for paying director's remuneration is a taxable receipt.
  • June 2021 - Tax Matters Issue No. 2021/06 (JMP Advisors)
    In this edition, we have discussed rulings which cover some contentious issues such as deduction towards profits and gains from eligible business cannot be restricted to business income; a miscellaneous application pending disposal is a disputed case eligible for settlement under VsV scheme; taxpayer should be given sufficient opportunity to put forth its case before framing orders under faceless regime; a capital receipt (forex gains) cannot be brought to tax unless specifically made chargeable to tax; and the recent circular extending due dates of certain income tax compliances for the FY 2020-21.
  • May 2021 - Tax Matters Issue No. 2021/05 (JMP Advisors)
    In this edition, we have discussed rulings which cover some contentious issues such as the applicability of the provisions of section 56(2)(viib) to shares issued in the course of amalgamation, benefit of the Most Favoured Nation clause under the Protocol to the DTAA, the applicability of the principle of natural justice in conducting scrutiny proceedings and some prerequisites to attract criminal liability, along with certain other important rulings and notifications.
  • April 2021 - Tax Matters Issue No. 2021/04 (JMP Advisors)
    In this edition, we have discussed the landmark judgement of the Hon’ble Supreme Court pertaining to taxation of software payments in the hands of non-residents along with certain other important rulings.
  • April 2021 - Newsletter Issue No. 3 (Hardwick & Morris LLP)
    In this third edition we cover some of the recent changes in tax law and other matters that we believe may be of interest to clients, contacts, and other advisers that we work with. The intention is not to provide a full technical update but to highlight some recent developments, provide some information on changes that may be of interest or relevance to you and to give an insight into some of the things we have been up to.
  • March 2021 - Insights Vol. 8 No. 2 (Ruchelman P.L.L.C.)
    In this month’s edition of Insights, the articles address implementation of the Mandatory Disclosure Directive known as D.A.C.6 in nine countries that are Member States of the European Union. D.A.C.6 established a framework designed to shine a light on cross-border tax plans potentially viewed as aggressive by European tax authorities.
  • March 2021 - Tax Matters Issue No. 2021/03 (JMP Advisors)
    The rulings in the newsletter contain some interesting issues including taxability of compensation received against Letter of intent, compensation received for pre-closure of a manufacturing contract, taxability of fees received for providing design services linked with a project office in India, whether booking of flat can be treated as construction of house for the purpose of exemption and extension of applicability of the LoB clause to the sale of shares of a Singapore based company.
  • March 2021 - H2CAT Newsletter Issue No. 2021/01 (Dr. Janet Yellen)
    Dr Janet Yellen is a very important person who was appointed Secretary of the US Treasury on January 26, 2021. At the US Senate Finance Committee hearing on her nomination 5 days earlier, Janet Yellen answered an array of questions, providing useful insights about her positions. So what does Janet Yellen stand for? How will it affect US persons and international business? Following are extracts from her hearing.
  • February 2021 - Insights Vol. 8 No. 1 (Ruchelman P.L.L.C.)
    French Treatment of Foreign Trusts. The French Trust Register was introduced in December 2013 by a law enacted to stop tax fraud and serious economic and financial crimes. In October 2016, the French Constitutional Court ruled that public access to the Trust Register was unconstitutional.
  • February 2021 - Tax Matters Issue No. 2021/02 (JMP Advisors)
    The Indian Finance Minister presented Budget 2021-22 in Parliament on 1 February 2021 against the backdrop of a subdued global economy in the face of the COVID-19 pandemic and the resulting health, humanitarian and economic crisis. Notably, Budget 2021-22 contains several welcome announcements aimed at revival of the economy.
  • January 2021 - Tax Matters Issue No. 2021/01 (JMP Advisors)
    The rulings in the newsletter contain some interesting issues including contrasting perspectives on “voluntariness” of a gift and gifts given with a view to restructuring and obtaining tax benefits, upholding of the charitable trust status of Tata Trusts, the timing of taxing Fees for Technical Services and taxation of subscription fees for online databases. The newsletter also touches upon the Press Release relating to UDIN and the notifications extending the due dates for various tax compliances.
  • December 2020 - Insights Vol. 7 No. 7 (Ruchelman P.L.L.C.)
    2020 Year in Review. As is our tradition at Insights, the December special edition acknowledges the contributions of guest authors throughout the year. Twelve articles written by 18 guest authors appeared in Insights 2020, down from 25 in 2019, when the world was unaware of the COVID-19 virus and worldwide lockdowns.
  • December 2020 - Newsletter Issue No. 2 (Hardwick & Morris LLP)
    In this second edition we cover updates on SEISS and our hot topic is the time to pay arrangements. With the Brexit transitional period coming to an end we also look at the VAT changes facing businesses and the Customs procedures that will need to be followed for imports and exports. There are some short reports on events which we have taken part in and a summary of another article for the Sports Law & Taxation journal, this time covering the employment status of referees which covers some areas that will be applicable to anyone considering whether they are employed or self-employed. Lastly, we have a guest article from Mala Kapacee, director of London Tax Network Ltd (and formerly of Gabelle). Mala is an expert in dealing with HMRC disclosures and tax investigations as well as being a well known writer on tax matters.
  • November 2020 - Insights Vol. 7 No. 6 (Ruchelman P.L.L.C.)
    Exchanges of Information in Tax Matters and Fundamental Rights of Taxpayers – E.C.J. Delivers Landmark Ruling in the Aftermath of Berlioz. In a post B.E.P.S. world, tax transparency is a mantra among stakeholders in government, media, and nongovernmental organizations.
  • November 2020 - Tax Matters Issue No. 2020/03 (JMP Advisors)
    In our newsletter this month, we have covered rulings by Courts/Tribunals in October 2020 on the following interesting topics: 1. Whether income tax implications are applicable at the time of issue of shares or at the time of share application? We have also discussed the challenges raised by the tax officer in the valuation. 2. Whether the beneficial rate of tax on dividend as per the Tax Treaty can be applied to the Dividend Distribution Tax rate. 3. Whether depreciation can be claimed by the successor company on revalued intangibles of a partnership firm? 4. Whether a pass-through entity can claim the credit for the tax deducted at source by the venture capital undertaking, under their PAN? 5. Whether indirect transfer of Indian assets before the amendment in the explanations to section 9 will attract capital gains taxation? 6. What are the implications for unintentional short deduction of tax deducted on sale of the property to a Non Resident? 7. Whether a beneficial rate of tax as per the tax treaty or Income Tax Act applies separately for each royalty agreement?
  • October 2020 - Tax Matters Issue No. 2020/02 (JMP Advisors)
    Key amendments brought in the Income-tax Act, 1961 by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.
  • September 2020 - Insights Vol. 7 No. 5 (Ruchelman P.L.L.C.)
    Home Thoughts from Abroad: When Foreigners Purchase U.S. Homes; Final G.I.L.T.I. High-Tax Regulations and the Tested Unit: Would a Rose By Any Other Name Smell as Sweet?;New Partnership International Information Return Schedules; When an Exchange of Vows is Followed by Separate Ownership of Shares Should Either Spouse Feel G.I.L.T.I.?; The Do’s and Don’ts of I.R.S. Transfer Pricing Storytime
  • September 2020 - Tax Matters Issue No. 2020/01 (JMP Advisors)
    Highlights of the Transparent Taxation platform unveiled by the Indian Prime Minister on 13 August 2020, comprising of three pillars – Faceless assessments, Faceless appeals and Taxpayers' Charter.
  • August 2020 - Insights Vol. 7 No. 4 - Corporate Taxation in Europe (Ruchelman P.L.L.C.)
    Outbound Acquisitions: Tax Planning For European Expansion In A Changing Landscape (2020); B.E.P.S. and Holding, Companies, European Tax Law, Luxembourg, Switzerland, Netherlands, Ireland, Spain, Portugal, United Kingdom, Belgium, Sweden, Denmark, Austria, France, Italy, Germany, Cyprus, Malta
  • August 2020 - Newsletter Issue No. 1 (Hardwick & Morris LLP)
    Internal News; Making Tax Digital (MTD) Update - Income Tax; Self-Employment Income Support Scheme (SEISS); Xavi Alonso & Geovanni: Image rights case comparison; CGT on Property Disposals; Job Retention Bonus
  • 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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