Podcast: Credit Funds: Withholding Tax on European Investments
Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more
The release of the Pillar One and Pillar Two “blueprints” in October 2020, and the recent G7 (June 2021) and G20 (July 2021) meetings, provided an opportunity for further progress to be made on the Pillar One and Pillar Two...more
The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question gave rise to a selective advantage under EU...more
TAX TIDBIT - New National Taxpayer Advocate. The Internal Revenue Service (IRS) announced that a new National Taxpayer Advocate will likely be in place by April. According to an internal memo sent by IRS Commissioner...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 24 – 28, 2020. February 24, 2020: The IRS released final instructions to Form 8978,...more
The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more
As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more
On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more
The Luxembourg Government has, on 4 August 2017, submitted a bill1 to Parliament for the reintroduction of a regime of taxation of intellectual property (IP) rights in Luxembourg. The new regime is intended to replace the...more
In Depth - UK Withdrawal Process - The United Kingdom will continue to be an EU member until procedures are completed for exiting the European Union, which is likely to be a long process. Under EU Treaty rules,...more
The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more