The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during November 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during October 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during September 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during August 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during June 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during May 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during April 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during March 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during February 2024

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during December 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during November 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during October 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during September 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during August 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during July 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during June 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during May 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during April 2023

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during March 2023

KEY DIRECT AND INDIRECT TAX TAKEAWAYS FROM BUDGET 2023.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during November 2022.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space and overseas direct investment regime during September 2022.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space and overseas direct investment regime during August 2022.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during July 2022.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during June 2022.

Newsflash summarising the guidelines provided by the Central Board of Direct Taxes (‘CBDT’) vide Circular no. 14 of 2022 dated 28 June 2022

Newsflash summarising the guidelines provided by the Central Board of Direct Taxes (‘CBDT’) by issuing Circular No. 13 of 2022 dated 22 June 2022.

Newsflash summarising the guidelines provided in Income tax Circular No. 12 of 2022 dated 16 June 2022.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during May 2022.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during April 2022.

News Flash on the key amendments to the Finance Bill, 2022 as passed by the Lower House of the Parliament on 25 March 2022.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during months of January and February 2022.

Detailed analysis of the Budget 2022-23 including the key policy and tax proposals.

The Indian Finance Minister presented Budget 2022-23 in Parliament on 1 February 2022 against the backdrop of a rebounding and recovering economy. Budget 2022-23 is growth oriented and forward looking and contains various timely announcements to spur growth.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during December 2021.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during November 2021.

The article explains the taxation of dividend income in India in the hands of non-resident shareholders and gives specific insights in this regard for tax residents of Mauritius, USA, UK, Singapore, Netherlands, Switzerland, Cayman Islands and BVI, amongst others.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during October 2021.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during September 2021.

The team at JMP Advisors is pleased to bring to you a gist of some of the significant developments in the direct tax space during August 2021.

In this edition, we have discussed case laws on some interesting issues such as advance given to the managing director in return for providing collateral security and personal guarantee towards loan taken by private limited company not taxable as deemed dividend.

The TLA 2021 proposes to dilute the impact of the retrospective amendments that were brought about by the Finance Act, 2012 which effectively made indirect transfer of assets located in India taxable in India retrospectively with effect from Financial Year 1961-62.

In this edition, we have discussed rulings which cover some interesting issues on set-off of brought forward business loss of earlier years against capital gain income; assessment order passed under section 143(3A) of the Income-tax Act, 1961 after 31 March 2021 is bad in law; income from Indian Depository Receipts is exempt under Article 22 of India- Mauritius DTAA; write-off of investment in loss making overseas subsidiaries is allowed as business loss; question of beneficial DTAA rate over Dividend Distribution Tax rate; sum received from holding company for paying director's remuneration is a taxable receipt.

In this edition, we have discussed rulings which cover some contentious issues such as deduction towards profits and gains from eligible business cannot be restricted to business income; a miscellaneous application pending disposal is a disputed case eligible for settlement under VsV scheme; taxpayer should be given sufficient opportunity to put forth its case before framing orders under faceless regime; a capital receipt (forex gains) cannot be brought to tax unless specifically made chargeable to tax; and the recent circular extending due dates of certain income tax compliances for the FY 2020-21.

In this edition, we have discussed rulings which cover some contentious issues such as the applicability of the provisions of section 56(2)(viib) to shares issued in the course of amalgamation, benefit of the Most Favoured Nation clause under the Protocol to the DTAA, the applicability of the principle of natural justice in conducting scrutiny proceedings and some prerequisites to attract criminal liability, along with certain other important rulings and notifications.

In this edition, we have discussed the landmark judgement of the Hon’ble Supreme Court pertaining to taxation of software payments in the hands of non-residents along with certain other important rulings.

In this third edition we cover some of the recent changes in tax law and other matters that we believe may be of interest to clients, contacts, and other advisers that we work with. The intention is not to provide a full technical update but to highlight some recent developments, provide some information on changes that may be of interest or relevance to you and to give an insight into some of the things we have been up to.

In this month’s edition of Insights, the articles address implementation of the Mandatory Disclosure Directive known as D.A.C.6 in nine countries that are Member States of the European Union. D.A.C.6 established a framework designed to shine a light on cross-border tax plans potentially viewed as aggressive by European tax authorities.

The rulings in the newsletter contain some interesting issues including taxability of compensation received against Letter of intent, compensation received for pre-closure of a manufacturing contract, taxability of fees received for providing design services linked with a project office in India, whether booking of flat can be treated as construction of house for the purpose of exemption and extension of applicability of the LoB clause to the sale of shares of a Singapore based company.

Dr Janet Yellen is a very important person who was appointed Secretary of the US Treasury on January 26, 2021. At the US Senate Finance Committee hearing on her nomination 5 days earlier, Janet Yellen answered an array of questions, providing useful insights about her positions. So what does Janet Yellen stand for? How will it affect US persons and international business? Following are extracts from her hearing.

French Treatment of Foreign Trusts. The French Trust Register was introduced in December 2013 by a law enacted to stop tax fraud and serious economic and financial crimes. In October 2016, the French Constitutional Court ruled that public access to the Trust Register was unconstitutional.

The Indian Finance Minister presented Budget 2021-22 in Parliament on 1 February 2021 against the backdrop of a subdued global economy in the face of the COVID-19 pandemic and the resulting health, humanitarian and economic crisis. Notably, Budget 2021-22 contains several welcome announcements aimed at revival of the economy.

The rulings in the newsletter contain some interesting issues including contrasting perspectives on “voluntariness” of a gift and gifts given with a view to restructuring and obtaining tax benefits, upholding of the charitable trust status of Tata Trusts, the timing of taxing Fees for Technical Services and taxation of subscription fees for online databases. The newsletter also touches upon the Press Release relating to UDIN and the notifications extending the due dates for various tax compliances.

2020 Year in Review. As is our tradition at Insights, the December special edition acknowledges the contributions of guest authors throughout the year. Twelve articles written by 18 guest authors appeared in Insights 2020, down from 25 in 2019, when the world was unaware of the COVID-19 virus and worldwide lockdowns.

In this second edition we cover updates on SEISS and our hot topic is the time to pay arrangements. With the Brexit transitional period coming to an end we also look at the VAT changes facing businesses and the Customs procedures that will need to be followed for imports and exports. There are some short reports on events which we have taken part in and a summary of another article for the Sports Law & Taxation journal, this time covering the employment status of referees which covers some areas that will be applicable to anyone considering whether they are employed or self-employed. Lastly, we have a guest article from Mala Kapacee, director of London Tax Network Ltd (and formerly of Gabelle). Mala is an expert in dealing with HMRC disclosures and tax investigations as well as being a well known writer on tax matters.

Exchanges of Information in Tax Matters and Fundamental Rights of Taxpayers – E.C.J. Delivers Landmark Ruling in the Aftermath of Berlioz. In a post B.E.P.S. world, tax transparency is a mantra among stakeholders in government, media, and nongovernmental organizations.

In our newsletter this month, we have covered rulings by Courts/Tribunals in October 2020 on the following interesting topics: 1. Whether income tax implications are applicable at the time of issue of shares or at the time of share application? We have also discussed the challenges raised by the tax officer in the valuation. 2. Whether the beneficial rate of tax on dividend as per the Tax Treaty can be applied to the Dividend Distribution Tax rate. 3. Whether depreciation can be claimed by the successor company on revalued intangibles of a partnership firm? 4. Whether a pass-through entity can claim the credit for the tax deducted at source by the venture capital undertaking, under their PAN? 5. Whether indirect transfer of Indian assets before the amendment in the explanations to section 9 will attract capital gains taxation? 6. What are the implications for unintentional short deduction of tax deducted on sale of the property to a Non Resident? 7. Whether a beneficial rate of tax as per the tax treaty or Income Tax Act applies separately for each royalty agreement?

Key amendments brought in the Income-tax Act, 1961 by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.

Home Thoughts from Abroad: When Foreigners Purchase U.S. Homes; Final G.I.L.T.I. High-Tax Regulations and the Tested Unit: Would a Rose By Any Other Name Smell as Sweet?;New Partnership International Information Return Schedules; When an Exchange of Vows is Followed by Separate Ownership of Shares Should Either Spouse Feel G.I.L.T.I.?; The Do’s and Don’ts of I.R.S. Transfer Pricing Storytime

Highlights of the Transparent Taxation platform unveiled by the Indian Prime Minister on 13 August 2020, comprising of three pillars – Faceless assessments, Faceless appeals and Taxpayers' Charter.

Outbound Acquisitions: Tax Planning For European Expansion In A Changing Landscape (2020); B.E.P.S. and Holding, Companies, European Tax Law, Luxembourg, Switzerland, Netherlands, Ireland, Spain, Portugal, United Kingdom, Belgium, Sweden, Denmark, Austria, France, Italy, Germany, Cyprus, Malta

Internal News; Making Tax Digital (MTD) Update - Income Tax; Self-Employment Income Support Scheme (SEISS); Xavi Alonso & Geovanni: Image rights case comparison; CGT on Property Disposals; Job Retention Bonus

Taxation of Real Estate Investment in Israel; U.K. Mandatory Disclosure Regime (DAC6); How Not to Borrow a Treaty: Smith v. Commr; Heads I Win, Tails You (I.R.S.) Lose – Not Anymore: Hybrid Dividends and Code §245A(e); Anti-Abuse Rules of Temp. Reg. §1.245A-5T – A New Cerberus for the U.S. Tax System; Help – My Exclusively Foreign Trust Now Has a U.S. Beneficiary! What Are the Issues a Trustee Will Now Face in 2020?; U.S.: CARES Act Loans and Business Tax Provisions and I.R.S. Announcements on Stranded Individuals; Corporate Matters: The Value of Par Value

Swiss Corporate Tax Reform: T.R.A.F. in a Nutshell; The Netherlands Introduces Compensation Regulation to Discourage “Dormant Employment”; The Multilateral Instrument and Its Applicability in India; Foreign Tokens – U.S. Tax Characterization: Questions and Discussion; O.E.C.D. to Use Hybrid Model to Develop Digital Economy Nexus and Profit Attribution Rules; Variety Is the Spice of Life: Alternate Tax Structures for a U.S. Individual Disposing of Foreign Real Property; Transfer of Business Contracts – I.R.S. Disagrees with Greenteam, No Capital Gains Without a Fight; J-5 Step Up Anti-Money Laundering in 2020, Sights Set on Central America

A gRett-able Situation: New Trends in German Real Estate Transfer Tax on Share Deals; Portuguese Taxation of Distributions from Trust Capital: A Critical Assessment; O.E.C.D. Unified Approach Garners Less Unified Comments from Europe’s Tech Producers and Users; Same Same, But Different: Taxation of the Sale of Stock of an Indian Company by a U.S. Person; German Supreme Tax Court Rules in Favor of Taxpayer – U.S.-German Repatriation Non-taxable

IR35 – Why Are U.K. Businesses So Concerned?; New Developments on the V.A.T. Regime of Holding Companies; 2019 Welcomes New Finnish Interest Deduction Limitations; Can Tax Authorities Demand Access to Audit Workpapers? Canadian Experience Follows U.S. Rule; O.E.C.D. on Digital Business – Seriously?!; Tax Authorities Eye Gsk-Hul Merger: Could Attract Tax on Long-Term Capital Gains and Brand Transfer; Trust Regulations and Payment Services: Dutch Law in 2019; Strategies for Foreign Investment in Indian Start-Ups; Austria, France, and Italy to Introduce Digital Services Taxes; Foreign Investment an U.S. Real Estate – A F.I.R.P.T.A. Introduction; The Impact of Brexit On German Taxes for Private Clients and Nonprofit Organizations; India and the Digital Economy – The Emerging P.E. and Attribution Issues; 2020 Will Mark the End of an Era: Swiss Corporate Tax Reform Accepted; 87 Reflections on My 66 Years in Public Accounting; C.J.E.U. Judgments on Danish Beneficial Ownership Cases; Employers in the Netherlands: Prepare for Changes to Labor and Dismissal Laws in 2020; India Budget 2019-20; Israeli C.F.C. Rules Apply to Foreign Real Estate Companies Controlled by Israeli Shareholders; Collecting Another Country’s Taxes – Recent Experience in the Canada-U.S. Context

Collecting Another Country’s Taxes – Recent Experience in the Canada-U.S. Context; How Soon Is Now? O.E.C.D. Starts Work on a Substitute for Unilateral Digital Economy Fixes; Domestic Partnerships Treated as Entities and Aggregates: New Approach for G.I.L.T.I. and Subpart F; Nonprofits: Creeping Commercialization and the Specter of Unrelated Business Income Tax; Saving Clementine: Improving the Code §163(j) Deduction; I.R.S. Releases Relief Procedures for Certain Expats While Warning Bells Ring for Others; S.A.L.T. Cap Repeal Case Dismissed; I.R.S. Placing Watchdog Agents in International Financial Centers

India Budget 2019-20; Israeli C.F.C. Rules Apply to Foreign Real Estate Companies Controlled by Israeli Shareholders; Do You Have to Withhold 30% on Payments to a Non-U.S. Independent Contractor?; Preferred Yet Neglected — A Plea for Guidance on Redemptions of C.F.C. Preferred Stock in the Wake of U.S. Tax Reform; U.S. Tax Litigation Update — The President’s Tax Returns and the New S.A.L.T. Cap; Corporate Matters: F.I.R.R.M.A. Proposed Regulations Expand C.F.I.U.S. Oversite on Foreign Investment; U.S. Taxation of Cloud Transactions and Digital Content Transfers: 20-Year-Old Regulations Finally Move with the Times; Cryptocurrencies — Latest Developments on Either Side of the Atlantic and Beyond

Holding Companies of Europe – Tax Planning for European Expansion in a Changing Landscape

C.J.E.U. Judgments on Danish Beneficial Ownership Cases; Employers in the Netherlands: Prepare for Changes to Labor and Dismissal Laws in 2020; The Devil in the Detail: Choosing a U.S. Business Structure Post- Tax reform; Debt Characterization and Deductibility Under Domesticated International Rules; Qualified Opportunity Zones: Second Set of Proposed Regulations Offers Greater Clarity to Investors; Is the 100% Dividend Received Deduction Under Code §245A About as Useful as a Chocolate Teapot?; Grecian Magnesite Put to Bed: Tax Court Ruling Affirmed On Appeal; Updates and Other Tidbits

India and the Digital Economy – The Emerging P.E. and Attribution Issues; 2020 Will Mark the End of an Era: Swiss Corporate Tax Reform Accepted; Reflections on My 66 Years in Public Accounting; Proposed F.D.I.I. Regulations: Deductions, Sales, and Services; Peeling the Onion to Allocate Subpart F Income – This Will Make You Cry!; Missed Opportunities – Tax Court Shows No Mercy for Indirect Partner; Corporate Matters: Delaware Law Allows L.L.C. Divisions; New York State Renews the Three-Year Clawback for Gifts; New York State Says No to Annual Pied-à-Terre Tax, Yes to Increased Real Estate Transfer Taxes

Austria, France, and Italy to Introduce Digital Services Taxes; Foreign Investment an U.S. Real Estate – A F.I.R.P.T.A. Introduction; The Impact of Brexit On German Taxes for Private Clients and Nonprofit Organizations; Anti-Tax Arbitrage the U.S. Way; The Responsible Party – Changes Effective May 2019; State and Local Tax Credit Programs – Businesses May Get What Individuals Cannot; It’s Time for Cayman Shell Entities to Come Out of Their Shells and Show Economic Substance; New Jersey Provides G.I.L.T.I. Guidance

Trust Regulations and Payment Services: Dutch Law in 2019; Strategies for Foreign Investment in Indian Start-Ups; F.B.A.R.’s – What You Need to Know; The I.R.S. Approach to Dependent Agent Status; More Permanent Establishments: The Dwindling Preparatory and Auxiliary Activities Exception; Democrats Turn to Tax Reform to Reduce Wealth Disparity; Who’s Got the B.E.A.T.? Special Treatment for Certain Expenses and Industries

Can Tax Authorities Demand Access to Audit Workpapers? Canadian Experience Follows U.S. Rule; O.E.C.D. on Digital Business – Seriously?!; Tax Authorities Eye GSK-HUL Merger: Could Attract Tax on Long-Term Capital Gains and Brand Transfer; Proposed Code §864(c)(8) Regulations Codify Tax on Gain from Sale of Partnership Interest; Proposed Amendments to F.A.T.C.A. Suggest Reducing or Deferring Withholding; Who’s Got the B.E.A.T.? A Playbook for Determining Applicable Taxpayers and Payments

New Developments on the E.U. V.A.T. Regime of Holding Companies; 2019 Welcomes New Finnish Interest Deduction Limitations; Additional Guidance on New Opportunity Zone Funds

2018 Year in Review - A Year of Guest Features

Alta Energy Affirms Treaty Benefits: A Canadian Case Study For Applying the M.L.I.; A Deep Dive Into G.I.L.T.I. Guidance; C-Corps Exempt From Full Scope of Foreign Income Inclusion; How To Handle Dual Residents: the I.R.S. View on Treaty Tie-Breaker Rules

Dutch Corporate Tax Reform: Dividend Tax Remains, A.T.A.D. Arrives, and Tax Rates Drop; Extension of German Taxation on Foreign Companies Holding German Real Estate; Transition Tax – Proposed Regulations Are Here; Qualified Business Income – Are You Eligible For A 20% Deduction? Part II: Additional Guidance

Germany – Anti-Treaty Shopping Rule Infringes on E.U. Law; Hybrid Mismatches: Where U.S. Tax Law and A.T.A.D. Meet; Opportunity Zone Tax Benefit – How Does It Work and Can Foreign Investors Benefit?

Holding Companies of Europe - Tax Planning For European Expansion in A Changing Landscape

Joint Audits: A New Tool To Combat Crossborder Tax Evasion; Coming To The U.S. After Tax Reform; Have You Inherited A P.F.I.C.? – What It Means To Be A U.S. Beneficiary

O.E.C.D. And European Commission Unveil Proposals On Taxation Of The Digital Economy; Managing A Transfer Pricing Exam? Wash Your Hands With Soap And Water; The F-1 Visa – Privileged U.S. Tax Status And How To Keep It

Failure To Prevent – The Future Of Adviser Obligations; New Tax Treaty Between France And Luxembourg: French Tax Implications For Investors; G.D.P.R. Is Imminent – Is Your U.S. Business Prepared?

A New Definition Of Permanent Establishment In Italian Domestic Income Tax Law; India Budget 2018-19; Changes To C.F.C. Rules – More C.F.C.'s, More U.S. Shareholders, More Attribution, More Compliance; Investing In U.S. Real Estate On A (Possibly) Tax-Free Basis

Doing Business Post-Brexit: What To Expect In The United Kingdom Qualified Business Income – Are You Eligible For A 20% Deduction? B.E.A.T.-Ing Base Erosion: U.S. Subjects Large Corporations To Anti-Abuse Tax

Impact of The Tax Cuts And Jobs Act on U.S. Investors in Foreign Corporations; A New Tax Regime For C.F.C.'S: Who Is G.I.L.T.I.?; Modifications To The Foreign Tax Credit System Under The Tax Cuts and Jobs Act; Circular Letter No. 25/E Clarifies Italy'S New Carried Interest Regime

2017 Year in Review – Looking Forward, Looking Back; The U.K. Trust Registration Service: Impact For Trustees; Austrian Guidance on Taxation of Bitcoin and Other Cryptocurrencies; Tax 101: Virtual Currency – What Is It? And How Is It Taxed?; A Year of Guest Features

Brazil 2017: Tax Developments For Business Transactions; New Transparency Register in Germany; Anti-Inversion Rules Are Not Just For Mega-Mergers – Private Client Advisors Take Note; The Sharing Economy Part 2: Governments Strike Back

An American In London: Due Diligence Observations; Double Dutch: Dividend Tax Reform Extends Exemption, Yet Tackles Abuse; The Changing Face Of Service Permanent Establishments; Swiss Federal Council Opens Consultation Process On Tax Proposal 17

Spontaneous Exchange Of Tax Rulings – The Swiss Angle; Tax Roulette: Buying A Business Jet In; 2017 – Why Following The Patriot's; Example May Lead To A Jackpot; A Case Of Nonacquiescence: I.R.S. Opposes Bartell Decision; Legal And Practical Strategies For Managing Tax Disputes In India

Caveat Dominus: A Comparison Of Post-Employment Entitlements In The U.S. And Italy When Executive Employment Is Terminated Without Cause; When The (Fake) I.R.S. Calls – Memoirs Of The Tax Phishing World; Foreign Partner Not Subject To U.S. Tax; On Gain From Redemption Of U.S. Partnership Interest

Outbound Acquisitions: Holding Companies Of Europe – A Guide For Tax Planning, Or A Road Map For Difficulty?

This article provides a quick summary of important points concerning the taxation of Canadian residential real estate for non-residents of Canada.

High-Speed Tax Reform: The U.K. Diverted Profits Tax & Restrictions On Corporate Interest Deductions; Qualified Small Business Stock & The Eb-5 Visa Program – An Attractive Combination For Potential Investors; Sale Of A Partnership Interest By A Foreign Partner – Is Rev. Rul. 91-32 Based On Actual Law Or Administrative Wishes?; I.R.S. Breaks The Silence With Rev. Rul.2017-09, Issues Guidance On "North-South"Transactions;

Economic Nexus Through Ownership And Use Of Intellectual Property; I.R.S. Information Exchanges & The Coordinated Tax Raids On Credit Suisse; Amazon Makes The C.U.T. – An Important Taxpayer Win, A Reminder To Consider Transactional Evidence; Tax 101: Taxation Of Intellectual Property – The Basics; Foreign Tax Credit May Not Be Available For Gains Derived Outside The U.S.

U.K. Drops Changes To Non-Domicile Regime, But Likely Not For Long; Value-Added Tax 101 – A Far Cry From A Border Tax; Cross-Border Complexities: What You Need To Know Before Your Non-U.S. Client Invests In The U.S.; Valuation – More Art Than Science

Pre-Immigration Planning: Drop-Off Trusts + Private Placement Life Insurance – If The Tools Fit, Use Them; A Look At The House G.O.P.'S; "Destination-Based Cash Flow With Border Adjustment"; India Budget 2017-18; New Developments In The World Of Reverse Like-Kind Exchanges

Swiss Corporate Tax Reform Postponed; Italy Introduces A 15-Year Preferential Tax Regime For Wealthy Individuals Taking Up Tax Residence In Italy; Proposed Directive On The E.U. Common (Consolidated) Corporate Tax Base - A Primer; India – Guidelines Issued For Determining Place Of Effective Management

U.K. Criminal Penalties For Improper Tax Planning – Could You Be Effected?; News On The French Front: Tax Law Changes For Corporations And Individuals; Income Taxation Of Trusts In Belgium; Trump And The Republican-Led Congress Seek Overhaul Of International Tax Rules

European Commission Rocking The Boat; At Arm's Length; Goods And Services Tax: A Game Changer; §385 Regulations Adopted With Helpful Changes, But Significant Impact Remains; French V. U.S. Share-Based Compensation Plans: A Comparative Anaysis

Spanish Tax Implications Of Nonresident Private Investment In Spanish Real Estate; Global Exchange Of Information: How Does The U.S. Fit Into The Puzzle?; Meet The U.S. Foreign Trust; European State Aid And W.T.O. Subsidies

Further Developments For U.K. Non-Dom Individuals; Treasury Attacks European Commission On State Aid – What Next?; Usufruct, Bare Ownership, & U.S. Estate Tax: An Unlucky Trio; Projected Tax Expense – Can It Be Computed On The Back Of Envelope?

European Registration & French Tax Law Create Pitfalls For U.S. Truststax 101: Foreign Settlors, U.S. Domestic Trusts, And U.S. Taxationcrowdfunding: A Popular Way To Invest, But Watch Out For Taxesa New Way To Do The Splits: B.E.P.S. Guidance Falls Short Of Enabling Global Formulary Apportionmentand More

The End Of The Negotiation: Protocol To India-Mauritius Tax Treaty Finally Released; French Life Insurance Policies: A U.S. Income Tax Perspective; E.U. State Aid – The Saga Continues

Canada Adopts Changes To Trust & Estate Taxation Rules; Italy Modernizes Tax Treatment Of L.B.O. Transactions; U.S. On The Blacklist – Is Delaware A Tax Haven?; Inbound §332 Liquidations & Inbound Asset Reorganizations

U.K. Adopts Public Register Of People With Significant Control Over U.K. Corporations; Inversions Under Siege: New Treasury Regulations Issued; Country-By-Country Reporting – Where Are We Going?; Transfer Pricing Positions Of Consolidated Groups: After Guidant

India Budget 2016-17; Exchange Of Information: Israel Inches; Toward International Norms; U.S. Treasury Announces New U.S. Model; Income Tax Convention; Corporate Matters: Anatomy Of A Limited; Liability Company Agreement – Part I

B.E.P.S. Initiative Spawns Unfavorable Permanent Establishment Court Decisions; Apple In Europe – The Uphill Battle Continues; Partnership Tax Traps And Recent Guidance; A Concise Guide To Acquisition Vehicles For The Purchase Of U.S. Real Estate By Foreign Individuals

The Common Reporting Standard – A Global F.A.T.C.A?; Taxpayers Take Note: I.R.S. Publishes Audit Guides For International Examiners; P.A.T.H. Act Leads To Widespread Changes; I.R.S. Adopts O.E.C.D. Standard In New Cbcreporting Regulations

A Guide To Non-Dom Taxation; Tax 101: How To Structure A Corporate Division; Anti-Inversion Rules Expanded; Congree Enacts Sweeping New Partnership Audit Rules

A Proposed Treatment For H.T.V.I.; President's Legislative Proposals; An Englishman In New York - Tax Considerations For Foreign Individuals; Russian Recovery Fund V. U.S.

The Past, Present, And Future Of Luxembourg Special Purpose Companies; Inadequate Gift Description – I.R.S. Tries For A Second Bite At The Apple; Final Stages Of B.E.P.S. Implementationand Its Effects; Corporate Matters: Are You Doingbusiness In New York?

The (Non) Recognition Of Trusts In Germany; Tax Court Strikes Down I.R.S. Position On Stock-Based Compensation In Altera Case; U.S. Taxation Of Carried Interest; Busy Month For B.E.P.S.

2015 Summer Budget Announced In U.K.; Tax Rulings In The European Union - State Aid As The European Commission's Sword Leading To Transparency On Rulings; Legislation To Relax F.I.R.P.T.A. Gets Bipartisan Support; U.S. Taxation Of Carried Interest; Can B.E.P.S. Survive Without U.S. Support?

Transfer Pricing Implications Of The B.E.P.S. Action Plan; "Trust" – A New Concept In Russia; Upcoming Regulations Could Limit A; Foreign Taxpayer's Refund Or Credit; U.K. Implements 25% "Google Tax" On; Diverted Profits

The Italian Voluntary Disclosure; J.C.T. Report On Competitiveness – A Step; Toward Consideration Of New Rules; Corporate Matters: Help – My Delaware Entity Has Been Cancelled!; Pre- Immigration Income Tax Planning,; Part Ii: Covered Expatriates

India Announces Ambitious Budget; For 2015-16; Debt Vs. Equity: Comparing Hp Appeal; Arguments To The Pepsico Case; Falciani: "The Man Who Makes The Rich; Tremble"; Mcdonald's Accused Of Re-Routing; Royalty Payments To Avoid Billions In; European Taxes; Using A §897(I) Non-Discrimination; Election To Avoid F.I.R.P.T.A.

Deoffshorization In Russia: C.F.C. Legislation Comes Into Effect; The Future Of Ireland As A Place To; Carry On Business In Light Of Recent; E.U. & O.E.C.D. Initiatives; U.S. Residency Certification: Pitfalls & Considerations; Tax 101: Understanding U.S. Taxation; Of Foreign Investment In Real; Property – Part Iii

The Proposed United Kingdom "Diverted Profits Tax"; Tax 101: Understanding U.S. Taxation Of Foreign Investment In Real Property – Part Ii; 2014 Tax Extenders Legislation Finally Approved; B.E.P.S. Update; Corporate Matters: Is Your Deal Safe?

Canadian Immigration Trust Exemption Withdrawn; Voluntary Tax Regularization: A U.S. And French Comparison; Foreign Correspondence: Notes From Abroad; Corporate Matters: Don'T Be Late – Time Is Of The Essence; Non-Willful Relief Expanded For Non-Filing Of Gain Recognition Agreement; A Bad Month For Luxembourg

Anti-Deferral Regimes: U.S. Taxation Of Foreign Corporations; Administrative Attack On Inversions; Tax 101: Understanding U.S. Taxation Of F.I.R.P.T.A. – Part I; Marks And Spencer: The End Of An Era?

Israeli Law Confronts International Tax Treaties And Principles Via New Treatment Of Mixed-Beneficiary Trusts; B.E.P.S.

Inbound Investment In German Real Estate; Tax 101: Updates To Procedures Relating To Withholding Foreign Partnership Or Trust Agreements As A Result Of F.A.T.C.A.; Current Tax Court Litigation Illustrates Intangible Property Transfer Pricing And Valuation Issues; Corporate Inversion Transactions: Tax Planning As Treason Or A Case For Reform?; Corporate Matters: Delaware Or New York L.L.C.?

The Mckesson Transfer Pricing Case; U.S.-Based Pushback On B.E.P.S.; Tax 101: Tax Planning And Compliance For Foreign Businesses With U.S. Activity; Corporate Matters: Convertible Note Financing; F.A.T.C.A. 24/7

Using The U.K. As A Holding Company Jurisdiction: Opportunities And Challenges; I.R.S. Announces Major Changes To Amnesty Programs; Tax 101: Outbound Acquisitions – Holding Company Structures; First Circuit Holds Corporation's Possessions Tax Credit Was Not Reduced; Corporate Matters: Professional Limited Liability Companies And Professional Corporations

Expatriation The Transatlantic Way: Overview Of The French And The U.S. Regimes; F.B.A.R. Update: What You Need To Know; Tax 101: Taxation Of Foreign Trusts; F.A.T.C.A. 24/7; O.V.D.P. Update

Swiss Trustees And Board Members Of Foundations Have To Prepare For F.A.T.C.A.; Tax 101: Transactions In Fx: A Primer For Individuals; Proposed Partnership Regulations Will Affect Partnership Deal Economics; Corporate Matters: Angel Investing: An Introduction; F.A.T.C.A. 24/7; New York Enacts Major Corporate Taxation Reforms

O.E.C.D. Discussion Drafts Issued Regarding B.E.P.S. Action 2 – Neutralizing The Effects Of Hybrid Mismatch Arrangements; The O.E.C.D.'s Approach To B.E.P.S. Concerns Raised By The Digital Economy; What Must Foreign Trusts And Family Corporations Do About F.A.T.C.A.?; Transfer Pricing – Bankruptcy Court Prevents I.R.S. From Pursuing Unsupported Transfer Pricing Claims; Corporate Matters: Shareholder Agreements

I.R.S. Vs. O.E.C.D. – How Are Tax Authorities Planning To Conduct Your Next Transfer Pricing Audit; The O.E.C.D. Announces Global Standard For Automatic Exchange Of Information; F.A.T.C.A. And Trusts: A Primer; The I.R.S. Extends The Time For Estate Tax Portability Election For Small Estates; Corporate Matters: Incorporation Basics

Year-End Review: Net Investment Income Tax; Year-End Review: F.A.T.C.A.; Year-End Review: I.R.S. O.V.D.P.; Non-Resident Alien Interest; Reporting Rules Upheld; I.R.S. Issues Regulations Regarding P.F.I.C. Reporting Requirements