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
Many crypto-asset service providers will soon be required to start collecting detailed information about customers and transactions and report to their national tax authorities annually. Such businesses must obtain a...more
La legislación fiscal de EE. UU., promulgada el 4 de julio, amplía las obligaciones de reporte para fideicomisos extranjeros y entidades con traspaso de ingresos, al tiempo que consolida disposiciones clave de la reforma de...more
The July 4 U.S. tax legislation expands reporting obligations for foreign trusts and pass-through entities while locking in key provisions from the 2017 reform. For attorneys and advisors to high-net-worth individuals, this...more
On 22 August 2025, the Luxembourg tax authorities issued a second circular (Circular) on the reverse hybrid entity rules, this time clarifying the exemption applicable to collective investment vehicles (CIV Exemption)....more
On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more
What do you need to know about the IRS and state tax complications of offshore investments? It is common to have international investments in your portfolio, not to mention business interests. How do you navigate the...more
Migration, redomiciliation, continuation - the process which has many names is increasing in popularity. Guernsey has experienced a notable increase in the inward migration of corporate vehicles from other jurisdictions....more
On Monday, 16 June 2025, the Senate Finance Committee released its version (the Senate Proposal) of the Section 899 retaliatory tax provisions that also are included in the “One Big Beautiful Bill Act” (the Act) that was...more
The One Big Beautiful Bill Act (the “Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...more
Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more
In the United States, we drive on the right side of the road. In Singapore, cars drive on the left. Mexico, meanwhile, has its own road signs and speed limits, which sometimes are viewed as suggestions....more
Welcome to Lost in Translation: Blunders in International Estate Planning; in this blog series, I will delve into the rarified world of international estate planning, shedding light on possible pitfalls and slip-ups....more
The “GILTI Conscience” podcast team, led by partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation on the various methods for resolving cross-border transfer pricing...more
Welcome to "Lost in Translation: Blunders in International Estate Planning." This blog series explores the rarified world of international estate planning, uncovering potential pitfalls and providing insights to navigate the...more
Welcome to “Lost in Translation: Blunders in International Estate Planning.” This blog series explores the rarified world of international estate planning, uncovering potential pitfalls and providing insights to navigate the...more
In this episode, Mike Burke, AGG Corporate partner and leader of the Ireland & Northern Ireland practice, explores U.S. tax considerations for foreign businesses scaling to the U.S., including issues such as the branch...more
Key Highlights - - SPAC IPO activity has declined but de-SPAC transactions have proven resilient. - U.S.-listed SPACs are searching for targets internationally, creating opportunities for Canadian companies. - Key...more
The global wave of the two-pillar solution to address base erosion and profit shifting, commonly known as BEPS 2.0, has formally washed ashore in Singapore. It is now certain that multinational enterprises (MNEs) with local...more
More special purpose acquisition vehicles (common known as “SPACs”) completed their initial public offering (“IPO”) in 2021 than in any prior year. In 2021, approximately 613 SPACs completed their IPO within the United States...more
The Organization for Economic Cooperation and Development (OECD) announced earlier today that 136 countries reached agreement on the Inclusive Framework on Base Erosion and Profit Shifting. The two-pillar framework would...more
IP rights with a nexus to Germany can create a variety of tax issues under German tax law. These include aspects of German or foreign IP rights generating “German source income,” questions of withholding tax obligations, a...more
On the eve of the UK's exit from the EU on 31 December 2020, the UK Government published the concise but game-changing piece of legislation, 'The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2)...more
Despite much anticipation to the contrary, the UK Government decided to repeal all but one of the reporting triggers under the UK regulations implementing EU Council Directive 2018/822 on the reporting of cross-border tax...more
On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and...more
Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more