- July 2017 - Taxation of Canadian residential real estate: what non-residents need to know
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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