GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
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
The IRS released Notice 2026-9, which provides a one-year extension to make certain amendments to individual retirement arrangements (IRAs), simplified employee pension arrangements, and savings incentive match plan for...more
In a landmark decision, the Supreme Court of India has ruled on the availability of tax treaty benefits and the taxation of indirect share transfers in the Tiger Global case. The Court upheld the Indian tax authorities’...more
In recent years, we have seen tax authorities increasingly relying on anti-abuse arguments to deny relief under double tax treaties. In this briefing, we consider three themes that have been coming up frequently in practice...more
Private clients investing in US-situs assets, such as interests in US real property or stock of a US corporation, take particular care to ensure that their investments are structured in a tax-efficient manner. For many...more
Texas continues to stand out as one of the most attractive U.S. real estate markets for Mexican investors seeking scale, stability, and long-term value. With its strong economic fundamentals, business-friendly legal...more
For a quarter of a century, the Venezuelan people have faced profound economic, social and institutional disruptions. For many high-net-worth families, these circumstances have meant not only the fragmentation of assets and...more
The OECD’s 2025 update to the Model Tax Convention marks a significant shift in how tax treaties address cross border remote work, natural resource activities and a number of important technical issues around transfer...more
On November 18, 2025, the OECD adopted the “2025 Update to the OECD Model Tax Convention” (Update), which includes broad-ranging updates to the OECD model treaty (Model Treaty). The most significant updates to the...more
Last year, in our article “OECD’s 2023 MAP and APA Statistics: Key Insights for Multinational Enterprises”, we analysed the inaugural global statistics on Advance Pricing Arrangements (APAs) alongside the longstanding mutual...more
The U.S. estate tax is a transfer tax on the value of property transferred at death. The tax applies differently depending on whether a person is considered a U.S. person or a non-U.S. person at the time of the transfer. For...more
Austria has approved the signing of Double Tax Treaty with Oman - On 24 September 2025, Austria has authorized the signing of the Double Tax Treaty (DTT) with Oman. The countries reached consensus on the draft DTT in March...more
In a general legal advice memorandum dated September 8, 2025, with a release date of September 19 (the “GLAM”), the Chief Counsel’s office of the Internal Revenue Service (“IRS”) addressed the application of the US branch...more
A federal district court recently upheld administrative summonses for phone records and personal data based upon a request made under a tax treaty. See Tirelli v. United States, No. 25-cv-04105-JSC (N.D. Cal. Aug. 28. 2025)...more
Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more
At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”)....more
Our latest episode of “GILTI Conscience” features an in-depth discussion on the complexities of profit attribution to permanent establishments (PEs) under international tax law. Skadden’s Nate Carden, David Farhat and Stefane...more
As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more
Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more
The recent decision of the Court of Justice of the European Union (CJEU) in C-601/23 Credit Suisse Securities (Europe) Ltd v. Diputación Foral de Bizkaia represents a transformative development in CJEU Case Law, one that...more
Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more
Decisions, Decisions - The owners of a closely held U.S. business will have to make many difficult decisions during the life of the business. Among the earliest of these is the so-called choice of business entity, the...more
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
Background - In GE Financial Investments Limited the Court of Appeal (“CoA”) overturned the Upper Tribunal’s (“UT”) decision and held that double taxation relief was not available under the UK-US double tax treaty (the...more
Maximiliano Concha Rodríguez is counsel with PAGBAM | Schwencke, Chile, the ILN's member firm. In this episode, Lindsay and Max chat about the unending tax reforms in Chile, the recent tax treaty between the US and Chile, and...more