Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
THE WONDER YEARS WEBINAR
Podcast: Credit Funds: Withholding Tax on European Investments
New anti-abuse provisions
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Background - In GE Financial Investments Limited the Court of Appeal (“CoA”) overturned the Upper Tribunal’s (“UT”) decision and held that double taxation relief was not available under the UK-US double tax treaty (the...more
Maximiliano Concha Rodríguez is counsel with PAGBAM | Schwencke, Chile, the ILN's member firm. In this episode, Lindsay and Max chat about the unending tax reforms in Chile, the recent tax treaty between the US and Chile, and...more
Double taxation arises when the same income is taxed in two different jurisdictions, potentially leading to excessive tax burdens for individuals and businesses. The UAE has developed a comprehensive legal framework to...more
In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more
The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more
It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign (i.e., non-U.S.) company, be a beneficiary of a foreign...more
This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
On Dec. 19, 2023, Treasury announced the entry into force of the U.S.-Chile bilateral income tax treaty (the Tax Treaty). The Tax Treaty is the first new comprehensive bilateral tax treaty signed by the United States to enter...more
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more
On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more
On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty) to the Chilean Congress for approval. Chilean tax practitioners...more
The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more
On June 22, 2023, the US Senate passed a resolution consenting to the ratification of the Income Tax Treaty between Chile and the United States (Treaty). The resolution opens the door for President Biden to formally ratify...more
There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more
Short Summary: The case discusses the validity of a closing agreement and if a taxpayer can set aside such agreement under malfeasance or misrepresentation of fact....more
U.S. Tax Residency Status - As a general matter, all U.S. citizens and U.S. residents are treated as U.S. tax residents. A non-U.S. citizen is generally classified as a nonresident for U.S. tax purposes unless they satisfy...more
Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD)...more
The US Treasury is moving to formally withdraw from the US-Hungary income tax treaty, which has been in effect since 1979 (the Treaty). For previous reporting by Eversheds Sutherland regarding the Treaty, see US-Hungary tax...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 31, 2022 – June 3, 2022... May 31, 2022: The IRS issued a press release, reminding...more
Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more
The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more
Withholding on Foreign Payments of FDAP - Income A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. ...more