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Feature

  • Civil Court of Paris, 32nd criminal chamber, 12 January 2017 - W Case

Case Summaries

Switzerland

  • AC Treuhand: Deductibility of fines for Swiss tax purposes and other implications to the tax sector

United States

  • 15 West 17th Street LLC v. Commissioner
  • Reporting offshore corporations and the lasting effects of noncompliance
  • Izen v. Commissioner, 148 T.C. No. 5 (1 March 2017)
  • The DOJ acts to foreclose against widow's home in Wyly Tax fraud case

Legislative Developments

Argentina

  • Tax Information Exchange Agreement between Argentina and the United States of America
  • Tax Information Exchange Agreement executed between Argentina and the United Arab Emirates
  • Release of repatriation and settlement obligations as regards the payment of services
  • Draft bill to establish corporate criminal liability

Colombia

  • Colombia new developments: UBO's and CFC's rules

European Union

  • Electronic filing of annual accounts will soon be mandatory

France

  • French-qualified Restricted Stock Units: introduction of a new post-Macron "hybrid" regime or the semi-unravelling of the Macron regime
  • Reinforcement of the impatriates' regime: Impatriate income tax regime of Article 155 B of the French Tax Code extended and exemption from payroll tax ("taxe sur les salaires")
  • Wealth tax and the anti-abuse mechanism regarding the capping mechanism
  • 80% penalty for undisclosed foreign assets
  • Modifications of wealth tax exemptions (as of the 2017 wealth tax)
  • Taxes on the cash balancing payment paid in share contribution or exchange transactions
  • Tax deferral measures: modification of reinvestment terms

Italy

  • Implementation guidelines on new beneficial tax regime for new residents

Malaysia

  • Automatic Exchange of Information and Common Reporting Standards in Malaysia

Spain

  • Ultimatum to Spain: EU Commission confirms declaration of assets kept abroad by Spanish taxpayers could be illegal

United Kingdom

  • New corporate criminal offence: failure to prevent facilitation of tax evasion
  • Tax evasion and the Criminal Finances Bill - 10 Things to Consider

United States

  • Tax debts put passports at risk
  • PFIC: Determining ownership and reporting requirements under new regulations
  • Transitional relief for equity-linked products but challenges remain
  • IRS issues new final qualified intermediary agreement
  • Is regulatory reform coming to Washington?
  • First Circuit rules against taxpayer on STARS transactions

Reflections

  • US estate tax repeal: What does it mean for global families?
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