International Tax Issues

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Doing Business in Latin America and The Caribbean: Columbia

Colombia is located in the northernmost part of South America. Its population is estimated at over 45 million people, with at least 10 million living in the capital city of Bogotá. Colombia’s main language is...more

Tax Information Exchange Litigation in Offshore Jurisdictions

There have been a number of decisions published recently by the courts in various international financial centres such as Bermuda, the Cayman Islands, Jersey and Singapore, that have considered the meaning and effect of...more

£1 Billion At Stake - Taxpayer wins compound interest on overpaid VAT

The High Court (Henderson J) handed down its decision on 28 March 2014 awarding the mail order and retail company, Littlewoods Retail Limited, compound interest on sums of overpaid VAT that had originally been reimbursed to...more

IRS Offers FATCA Relief, Extending Registration Deadline and Expanding Intergovernmental Agreement List

On April 2, 2014, the U.S. Internal Revenue Service (IRS) issued Announcement 2014-17 (the Announcement), which provides certain FATCA relief. The Announcement extends from April 25, 2014 to May 5, 2014 the deadline by which...more

Doing Business in Latin America and The Caribbean: Chili

Chile’s business environment is the result of a policy-driven strategy that has focused on building sound macroeconomic fundamentals and strong institutions, promoting competition and international integration, and creating a...more

Blame It on the Bossa Nova! A One Note Samba for Inbound Real Estate in the U.S

As an undergraduate at West Point, I was a Spanish and Portuguese major. My Brazilian “thing” had already started a decade earlier as a ten year old growing up in the Panama Canal Zone seeing Pele play for his Brazilian team...more

Doing Business in Latin America and The Caribbean: Cayman Islands

The Cayman Islands are located in the western Caribbean Sea about 480 miles south of Miami and 180 miles northwest of Jamaica. Of the three islands, Grand Cayman is the largest with an area of 76 square miles. The islands of...more

Doing Business in Latin America and The Caribbean: Brazil

With more than 196 million inhabitants and over 8.5 million square kilometers, Brazil is the largest country and economy in Latin America (its GNP in 2011 was roughly USD2.07 trillion). It is a federative republic, consisting...more

Doing Business in Latin America and The Caribbean: Bolivia

Bolivia is a country with amazing natural beauty and a diverse landscape, sheltering a fourth of the world’s greatest biodiversity. Bolivia’s riches also include raw material, industrialized material and of course, tourism....more

Australian Businesses Supplying Electronic, Telecoms And Broadcasting Services To EU Customers Need To Be Aware Of Changes To EU...

EU VAT CHANGES FOR E-COMMERCE SERVICES - Australian e-commerce businesses that supply services to European customers need to be aware of important "value added tax" ("VAT") changes that will apply across the European...more

UK Enters into Tax Agreements with the Cayman Islands and Other Offshore Jurisdictions

The UK and the Cayman Islands recently entered into an agreement to improve international tax compliance (ITC). Similar to the US Foreign Account Tax Compliance Act (FATCA), the ITC imposes wide-ranging UK financial reporting...more

"OECD Draft Report: The Digital Economy and Its Tax Challenges"

On March 24, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on the tax challenges facing the digital economy (the DE Report). This draft report is issued in...more

International Tax News - March 2014

NETHERLANDS: TAX TREATMENT OF HYBRID FINANCE INSTRUMENTS IN THE WAKE OF TWO LANDMARK CASES - The Dutch Supreme Court has given its judgment in two landmark cases regarding the classification of hybrid finance...more

Netherlands: tax treatment of hybrid finance instruments in the wake of two landmark cases

The Dutch Supreme Court has given its judgment in two landmark cases regarding the classification of hybrid finance instruments. The question in both cases was whether shares can be requalified as a debt instrument for...more

Doing Business in Latin America and The Caribbean: Argentina

Bordering the south Atlantic Ocean, Argentina is the second largest country in South America. Argentina’s population is over 40 million people, and the country is organized as a federal republic consisting of 23 provinces and...more

UK Budget 2014 – Key Tax Measures

Apart from personal taxation measures intended to be attractive to voters, the Budget is perhaps much less controversial than in previous years. Many of the detailed taxation provisions intended for inclusion in Finance Bill...more

Israel's 10-Year Tax Holiday for Immigrants Is No Tax Haven for Ex-Pats

While Israel welcomes immigrants, and even provides them with tax incentives, it is serious about ending any perceived notion that it is somehow complicit with taxes evaded by its foreign residents in their home country. As...more

Businesses Face More Onerous Transfer Pricing Documentation and Country-by-Country Tax Reporting

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a...more

International Tax News - February 2014

IRS RELEASES ITS “ROADMAP” OF THE TRANSFER PRICING AUDIT PROCESS - The US Internal Revenue Service has released its Transfer Pricing Audit Roadmap, a 26-page outline of the two-year transfer pricing audit process,...more

Camp unveils major tax reform plan

Yesterday, House Ways and Means Committee Chairman Dave Camp (R-Michigan) unveiled his comprehensive tax reform proposal. Released as draft legislation, the Camp proposal calls for the most fundamental reform of the tax code...more

Tax Litigation Update: Eleventh Circuit Reverses Tax Court in Virgin Islands EDP Residency Cases

We have written extensively about the United States Virgin Islands Economic Development Program (EDP) and the litigation it has spawned between and among the IRS, the Virgin Islands Bureau of Internal Revenue (VIBIR), and the...more

International Disclosure Obligations: "Beyond FATCA" - Further Developments in the Laws On Automatic Information Exchange and...

The U.S. information reporting and withholding tax regime known as "FATCA"[1] was signed into law on March 18, 2010. In the nearly four years since, the attention of international financial institutions of every variety,...more

"OECD Releases Global Standard for Automatic Exchange of FATCA-Type Information"

As part of a push for greater transparency, the Organization for Economic Cooperation and Development (OECD) released on February 13, 2014, a Common Reporting Standard (CRS) for Automatic Exchange of Financial Account...more

Supreme Court Rules on Rectification Remedy Under Québec Civil Law in the Tax Context

The question whether rectification of contracts is a remedy available to parties under the Québec Civil Code (CCQ), previously unsettled in Québec civil law, was answered in the affirmative by the Supreme Court of Canada in...more

Canada And U.S. Finally Reach Agreement On FATCA

The long awaited Foreign Account Tax Compliance Act United States – Canada Intergovernmental Agreement (IGA) was released on February 5, 2014, and as anticipated will expand the sharing of information between the two...more

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