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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Development of court practice of determining direct capital investment for the purpose of applying the 5% withholding tax rate...

by Dentons on

On 3 May 2017 the Commercial Court of Chelyabinsk Region rendered a decision in case No. ?76-20508/2016 under the claim of Chelyabenergosbyt PJSC (the “Company”)....more

OTA & Travel Distribution Update - April 7th, 2017

by Garvey Schubert Barer on

Below please find this week’s OTA & Travel Distribution Update for the week ending April 7, 2017. The recently released European Commission’s report on the hotel industry headlines this week’s Update. - European...more

Evidentiary Problems with Threat of Injury Findings in Canadian Trade Remedy Cases

by Bennett Jones LLP on

The recent proliferation of affirmative threat of injury findings by the Canadian International Trade Tribunal (CITT) indicates problems with the CITT’s approach to its threat of injury analyses. The CITT is arguably applying...more

Australian Tax Alert: Australia Pursues Multinational Tax Avoidance

by DLA Piper on

In the context of the imminent release of the OECD report to G20 finance ministers (in October 2015) dealing with its final recommendations on the Base Erosion Profit Shifting (BEPS) Action Plan, Australia has introduced...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

by Dechert LLP on

Enforcement – FCA Fines £13.2 Million for Transaction Reporting Failures - The FCA fined Merrill Lynch International (MLI) £13.2 million on 22 April 2015 for incorrectly reporting 35,034,810 transactions and failing to...more

"Government Enforcement: Aggressive Efforts Continue Around the Globe"

Government enforcement efforts in 2013 produced major settlements of matters relating to the global financial crisis, high-profile insider trading convictions, near-record amounts of FCPA settlements, and new pledges of...more

Fiduciary Liability and Offshore Assets

by Sanford Millar on

Fiduciaries, like trustees and conservators, may face personal liability for wrongful acts in administering estates. Among the liabilities that a fiduciary may face is to the IRS for wrongful distributions such as those made...more

So, You inherited an unreported offshore account, now what!

by Sanford Millar on

There may have been a time when inheriting an unreported offshore financial account was not problematic; but not today. The executor/trustee of the estate of the decedent has fiduciary responsibility to IRS and faces personal...more

Orrick's Financial Industry Week In Review - July 15, 2013

In This Issue: Financial Industry Developments; Rating Agency Developments; RMBS and Other Securities Litigation; and, European Financial Industry Developments. ...more

IRS Victory In FBAR Wilfulness Penalty Case

by Charles (Chuck) Rubin on

In an unpublished opinion, the Fourth Circuit Court of Appeals in U.S. v. Williams, reversed the district court’s holding that the taxpayer’s failure to file Form TD F 90-22.1 (“FBAR”) was not willful and in so holding, gave...more

France: Introduction of New Anti-Abuse Rules on the Tax Deductibility of Interest and other Financing Expenses

Until recently, private-equity investment funds and international corporate groups investing in France enjoyed a very favorable tax environment, including inter alia the benefit of both EU Directives and the double tax...more

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