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
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 a move to enhance Hong Kong’s status as a global business and financial hub, and to attract foreign companies to take advantage of Hong Kong’s taxation system and professional services–thereby encouraging investment and...more
Withholding Tax Rules Under Current Law - Current US tax law provides for a 30% withholding tax on interest paid by a US borrower to foreign lenders. However, many foreign lenders are exempt from this tax, either under the...more
As Republicans in the U.S. Senate now consider the reconciliation bill, they will need to consider what tax provisions contained in the One Big Beautiful Bill (OBBB), passed by the U.S. House of Representatives on May 22,...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
Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...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
The Spanish Tax Court clarified that a sale and lease-back transaction carried out between an entity and a bank does not qualify as a supply of goods (here Real Estate) for VAT purposes, but as a financing transaction....more
In Target Group Ltd v HMRC [2023] UKSC 35 (“Target”), the United Kingdom’s Supreme Court has held that the loan services which the taxpayer company provided to a bank were not exempt from VAT. ...more
This dispute arose when the Canada Revenue Agency (“CRA”) reassessed President’s Choice Bank (“PCB”) for uncollected GST/HST on bundled supplies made to a major Canadian bank (the “Bank”) and denied the Bank’s rebate claims...more
The resounding theme for the 2023 G20 summit, held on 9th and 10th September in India, has been “Vasudhaiva Kutumbakam” – an ancient Sanskrit phrase meaning “the world is one family.” The term perfectly juxtaposes...more
On June 27, 2023, the Tax Court of Canada (“TCC”) dismissed the appeal of a Schedule II bank (the “Bank”) regarding its entitlement to input tax credits (“ITCs”) for GST/HST payable on expenses incurred in connection with the...more
On June 8, 2023, the Federal Court of Appeal upheld a Tax Court of Canada decision that, by allowing a supplier of Automated Teller Machines (“ATMs”) to place and operate ATMs throughout its casino resort, a casino operator...more
On July 19, 2022, the Tax Court of Canada (“TCC”) dismissed a major Canadian Bank’s appeal (the “Bank” or the “Appellant”) regarding the characterization of a supply made by the President’s Choice Bank (“PCB”) to the Bank....more
On January 7, 2022, the European Commission adopted a draft regulation adding the Cayman Islands to its list of countries with strategic deficiencies in their AML/KYC regimes. Article 4 of the EU Securitisation Regulation...more
Italian tax authorities address for the first time the VAT regime applicable to the assignment of NPLs. On the very last day of 2021 the Italian Revenue Agency issued a remarkable ruling (no. 79/E) on the VAT regime...more
ASIC has released its third quarter update on corporate finance regulatory activities. From an M&A perspective, the update includes ASIC's observations on its public M&A deal statistics, outlines ASIC's recent concerns in M&A...more
Possible Future Risk for U.S. Financial Services Companies - Global digitalization spurred by rapid advances in digital technology is enabling virtual business operations at a frenetic pace, including by insurance and other...more
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
Takeaways - While the Trade and Cooperation Agreement (TCA) includes new commitments by the parties on tax, certain EU-derived tax rules will remain relevant in the UK. - That is actually a good thing in one respect: UK...more
The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK ...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
COVID-19 has not only created red tape for us—sheltering-in-place, staying six feet away from others, wearing masks in public—but it also has created new red tape for lenders. Each day new federal and state legislation, as...more