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
In October 2020, the Organization for Economic Co-operation and Development (“OECD”) Secretariat released a report addressing its “Pillar Two” blueprint for an overhaul of the international tax system. Pillar Two provides for...more
As we embark on our third year of Latin America Focus, the ever-evolving landscape in the region brings fresh opportunities and challenges for local, regional and international businesses. After an extremely positive...more
Adoption of the OECD Pillar Two model rules implementing accords on a global minimum corporate tax rate may result in anomalous or unfair results for some multinationals. Protections available under investment treaties,...more
On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more
Although no major tax reform was adopted in Mexico as part of the 2023 Economic Package, changes at an international level and some being brought at the regulatory level could have significant implications for different...more
Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more
This article is produced by our European Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the international tax environment. The last...more
After nearly a decade of being put on hold, several members of the Senate Foreign Relations Committee have recently indicated that the first US-Chile Income Tax Treaty is expected to be approved by the end of the year. The...more
On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more
Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more
On 6 July 2018, the UK Government published draft legislation to extend the territorial scope of UK tax by bringing capital gains realised by non-UK resident investors from UK real estate within the scope of UK taxation with...more
On 6 July 2018 the UK Finance Bill 2019 was published by the UK Government. The draft Finance Bill contains the details of the new regime on taxation of non-UK resident investors in UK real estate that had been proposed in a...more
The UK Government has announced in today’s Budget (22 November) that it is launching a consultation on extending the scope of UK tax on real estate. Currently, non-UK residents who are investors in UK land and buildings...more
The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more
International investment funds are set to benefit from measures issued by the Bank of Italy, aimed at facilitating direct investment into the country by EU alternative investment funds....more
India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more
Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the After-Tax Investment Return of Foreign Investors in MLPs - Overview - Master Limited Partnerships are publicly traded partnerships....more
On 31 March 2015, the Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this...more
According to recent estimates, the number of wealthy Russians investing in the United States ballooned in 2014 as a result of political turmoil and a disintegrating ruble causing Russians to seek a safe haven for their wealth...more
On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more
Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more
All “modern” income tax treaties concluded by the United States contain a “Limitation on Benefits” (LOB) provision. The purpose of such a provision is to prevent “treaty shopping.” Romania is one of the few remaining...more
Overview - Master Limited Partnerships are publicly traded partnerships. As of 2010, the market capitalization of MLPs was $220 billion. These publicly traded partnerships invest primarily in energy and associated...more
Yesterday, Reps. Kevin Brady of Texas and Joseph Crowley of New York proposed a major reform to the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R. 2870, the Real Estate Investment and Jobs Act of...more