Taxing Intelligence: AI's Role in Modern Tax Administration
The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
Impuesto de Timbre, ¿otra vez?
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
Ley Mbappé
Nonprofit Basics: International Grantmaking Part 3 -Special Rules for Private Foundations
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more
On July 4, 2025, the legislation commonly known as “The One Big Beautiful Bill Act” (the “BBBA”) was enacted. The BBBA makes permanent, extends and, in certain cases, modifies, a number of provisions from the 2017 Tax Cuts...more
To bring Hong Kong’s Foreign-Sourced Income Exemption (FSIE) regime in line with the European Union’s updated guidance on FSIE regimes promulgated in December 2022, the Inland Revenue (Amendment) (Taxation on Foreign-sourced...more
Following the UK Government’s 6 March announcement of tax reforms for the current “non-dom” tax regimes, the opposition Labour party has begun to outline how its plans would differ if they win the next UK general election. In...more
La Cour administrative d'appel de Paris rejette la requête de l'administration fiscale tendant à la requalification en salaires de gains réalisés par la holding personnelle d’un dirigeant lors de la cession de titres acquis...more
Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more
On November 21, 2023, the Government of Canada released its Fall Economic Statement. Among the measures included in the statement are improved tax incentives for Employee Ownership Trusts (“EOTs”)....more
The UK tax legislation imposes an “exit tax charge” on the unrealised capital gains of a company which migrates from the UK. The exit of a taxpayer (or their assets) is generally the last point in which a taxing jurisdiction...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more
Unexpectedly, it is likely the changes to the Luxembourg-UK double tax treaty will not be effective until 2024 at the earliest. Where that is the case, some Luxembourg investors in UK property rich entities will have another...more
More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more
The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more
The Spanish Parliament has finally approved Law 11/2021, of 9 July, on measures to prevent and fight against tax fraud (“Law 11/2021”) which implements several aspects of Council Directive (EU) 2016/1164 of 12 July 2016...more
The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more
UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
The Office of Tax Simplification (OTS) has published its first report following its review of certain aspects of the UK’s capital gains tax regime requested by the Chancellor in July this year with the specific purpose of...more
On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more
On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...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
UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...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
EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more
On February 4th, 2019, the Belgian government released a draft law ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "Convention") and the...more
A Presidential Decree by Mexico President Andrés Manuel López Obrador granting a new set of income tax incentives to capital gains and interests derived from corporate bonds (the Decree) became effective on Jan. 9, 2018. ...more