HMRC has released a consultation document in respect of its draft regulations implementing the EU mandatory tax disclosure rules that will apply from 1 July 2020 to intermediaries and relevant taxpayers in relation to...more
As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more
Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more