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
On August 22, 2024, Germany’s Federal Fiscal Court (Bundesfinanzhof) published a decision that refocuses attention on the complexities of cross-border taxation, particularly for Luxembourg-based funds investing in Germany....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
Introduction - Much of the current litigation between taxpayers and the United States has centered on the definition of willfulness or whether the non-willful FBAR penalty should apply on a per year or per account basis. ...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
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
The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...more
During an address to the Parliament’s Mazhilis on 11 January 2022, the president of Kazakhstan instructed the respective state bodies to “secure a strict monitoring, inspection, and control of all transactions and persons who...more
This morning, I woke up to news in the Wall Street Journal that indicated that the United States and the Republic of Malta had entered into a Competent Authority Agreement (“CAA”). Generally, this news would not have caught...more
The IRS recently concluded its 2021 four-part series of the “Dirty Dozen” tax-related scams. The fourth installment focuses on what the Service refers to as “schemes peddled by tax promoters, including syndicated...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more
Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more
Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more
The Kazakhstan Tax Code may change so that controlled foreign corporation rules will not apply to foreign persons that are residents of countries having a double tax treaty with Kazakhstan. Kazakhstan residents (both...more
The law of 20 June 2020 extended the measures concerning the holding of meetings in companies and other certain legal persons without the physical presence of the participants, initially provided for in the Grand Ducal...more
In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more
IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more
After nearly a decade of being put on hold, several members of the Senate Foreign Relations Committee have recently indicated that the first US-Chile Income Tax Treaty is expected to be approved by the end of the year. The...more
The guidelines for determining an Individual’s tax residency are as follows: - An Individual Taxpayer is a resident based on the laws of one treaty-partner country and is considered to be a resident of that country for...more
• The Swiss Federal Tax Administration published a new circular letter on lump-sum taxation. • The circular sets out a minimum taxable income of CHF 400,000 even if the living expenses are lower. • The stricter rules...more
Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more