US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
THE WAY WE WERE
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...more
In late March 2020, we published a note regarding the de-facto “downgrade” of the Cayman Islands by the European Union’s Economic and Financial Affairs Council (ECOFIN) as a “non-cooperative jurisdiction” for tax purposes....more
The European Council has announced its decision to remove the Cayman Islands from the EU list of non-cooperative jurisdictions for tax purposes. In February we reported on Cayman’s inclusion on the list and our expectation...more
In his address to the nation on 25 March 2020, the Russian President requested the government to implement measures ensuring the adequate taxation of Russian-sourced dividend and interest payments to "offshore" jurisdictions....more
On 18 February 2020, the ECOFIN committee of finance ministers of the EU resolved to add the Cayman Islands to the EU blacklist of non-cooperative jurisdictions for tax purposes. Their reasoning was short...more
The European Union has updated its list of non-cooperative tax jurisdictions to include the Cayman Islands. This addition could have certain repercussions for fund managers, sponsors, and investors operating through the...more
UK Case Law Developments - Valid notice crucial to tax indemnity claim - The Court of Appeal (CA) decision in Stobart Group Ltd v Stobart and another is a cautionary tale for any purchaser who, following the...more
Il Consiglio Europeo dei ministri dell'economia ha approvato e pubblicato una lista di 17 Paesi considerati paradisi fiscali (c.d. "Black List") e una lista di 47 Paesi che si sono impegnati ad allinearsi e rispettare i...more
PANA Issues Recommendations to European Parliament: Tougher Enforcement, Greater Transparency, Improved Information Sharing and Prohibitions Against Outsourcing of Customer Due Diligence....more
Starting on April 27, and finishing on May 2, the European Parliament (EP)’s Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) is holding two meetings to present several related studies which...more
Earlier this week, we blogged about how the United States recently declared the Philippines to be a “major money laundering country.” On the same day of our post, March 7, the European Parliament (EP) issued a Report which...more
What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more
On April 30, 2014, Josef Dorig, 72, of Switzerland, pleaded guilty in federal district court in Alexandria, Virginia, to a single count of Klein conspiracy: conspiracy to defraud the U.S. by impairing and impeding the IRS....more
The rapid evolution of the Foreign Account Tax Compliance Act (“FATCA”) from a U.S. driven effort to crack down on U.S. offshore tax evaders into an information reporting mechanism being considered for adoption throughout the...more
The IRS continues to aggressively pursue offshore tax evasion. Another example of which is plan to share tax information with Australia and the United Kingdom....more