Tax Law › International Law & Trade › Business Torts

IRS Victory In FBAR Wilfulness Penalty Case

In an unpublished opinion, the Fourth Circuit Court of Appeals in U.S. v. Williams, reversed the district court’s holding that the taxpayer’s failure to file Form TD F 90-22.1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