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
The Common Reporting Standard (CRS) was developed by the Organisation for Economic Co-operation and Development (OECD) to promote tax transparency by enabling tax authorities in one jurisdiction to receive information...more
As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more
In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
Jersey and Guernsey have long been recognised as leading international investment hubs, offering asset managers a compelling mix of professional and lifestyle advantages....more
Back in November 2023, the Amsterdam High Court ruled that the interest received by X BV (a notary firm) for funds in its trust account qualifies as VAT exempt turnover. According to the High Court, the interest received by X...more
Le 7 avril 2022 (le « jour du Budget »), la ministre des Finances du Canada a présenté le budget fédéral de 2022 (le « Budget 2022 »). Certains contribuables ont peut-être été soulagés de constater que le Budget 2022 ne...more
On April 7, 2022 (Budget Day), the Minister of Finance introduced Canada’s 2022 Federal Budget (Budget 2022). While taxpayers may be relieved that Budget 2022 does not include an increase to the capital gains inclusion rate...more
On March 22, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued proposed rules for the collection and exchange of information on transactions involving crypto-assets. The OECD intends for these...more
At the latest Trade & Export Finance webinar, Sam Fowler-Holmes, a partner in the Trade & Export Finance Group at Sullivan's London office, gave some valuable insight into what to consider before using a special purpose...more
The Spanish Official Gazette published last October 16th legislation enacting a new indirect Tax on Financial Transactions levied, at 0.2%, on the acquisition of shares of major Spanish listed companies irrespective of the...more
The Situation: For years, the Italian tax system has provided for certain tax deductions from income taxes in case of building restoration works. The Result: The tax deduction from income taxes has now been increased to...more
U.S. Developments - Federal and State Regulatory Developments - Bill in Hawaii State Senate Addresses Digital Assets Including Authorization for Banks to Serve as Qualified Custodians - SB 2594 before the Hawaii...more
SPECIAL REPORT - BREXIT: CHALLENGES AND OPPORTUNITIES - In this report, we explain some of the key legal implications associated with the United Kingdom leaving the European Union (EU) without a deal for future...more
In this reprint of his 2014 article, Rick leveraged his past working relationship to Jean Claude Juncker to accurately predict the unprecedented tax policy success of the Juncker Commission. Jean-Claude Juncker,...more
• Switzerland’s privileged taxation of companies is no longer in line with international standards. • In 2017, the first attempt to abolish the internationally criticized regime was clearly rejected by Swiss voters. • On 28...more
Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more
China’s open door policy is further opening up to welcome the world for business. The country is now building a landmark megalopolis on its southern coast with the name the “Greater Bay Area” (the “GBA”). ...more
The initial year of the Trump administration colored much of the political, business, and financial headlines of 2017, both in the U.S. and abroad. Key administration-related developments in 2017 included U.S. withdrawal from...more
Talk about a regulation with teeth. Within days of the Treasury Department announcing new rules meant to discourage corporate tax inversion deals, Pfizer and Allergan announced they were scrapping their planned $152 billion...more
On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more
This breakfast session is jointly presented by Sheppard Mullin and Bird & Bird LLP, and will look at the key issues to consider when structuring financings involving European counterparties and examine whether there are real...more