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ITSG Global Tax Journal   December 2019 - Volume 2 No. 5

India Introduces Optional Lower Corporate Tax Regime to Boost Economy
By Sakate Khaitan and Abbas Jaorawala (India)

Canadian Tax 101 – An Introduction to the Foreign Investor
By Dean Smith (Canada)

John Chown – A Look Back on My Career
By John Chown (United Kingdom)

Arnold Sherman – Some Thoughts on My Life as an International Tax Consultant
By H. Arnold Sherman (Canada)

  • 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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