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Feature

Jersey

  • Jersey Court summarizes best practices for trustees contemplating a Beddoe application

Case Summaries

France

  • Specific tax regime for impatriates provided by Article 155 B of the French Tax Code: a period of "International Voluntary Service in Business" in the United States is not taken into account when assessing the non-tax residence condition
  • "Lupa:" a glimmer of hope…?
  • Free revaluation of its buildings by an SCI and election of its shareholders to be subject to corporate income tax
  • Unconstitutionality of the 3% tax on dividend distributions: the end!
  • Is the withholding tax set forth by Article 119 bis, 2 of the French Tax Code contrary to the EU principle of free movement of capital?
  • The EUCJ declares that the anti-abuse rule of Article 119 ter of the French Tax Code regarding dividends paid before 1 January 2016 constitutes a breach of EU law
  • Characterization of a permanent establishment in France: tax relief in front of the tax court but tax fraud conviction in front of the criminal court
  • How to tax the premium received by a French football player for his participation in the football World Cup?

United States

  • Grecian Magnesite Mining and Potential Legislative Developments under the Tax Cuts and Jobs Act of 2017

Legislative Developments

Argentina

  • Argentina announces tax reform plan
  • New law - corporate criminal liability
  • Tax Information Exchange Agreement between Argentina and the United States of America enters into force

Brazil

  • Federal Government issues Provisional Measure altering the tax treatment applicable to investment funds
  • Report of Transactions Liquidated in Cash (DME)

Canada

  • Canada bans facilitation payments under foreign anti-corruption law

China

  • China signs multilateral instrument: impact on China's tax treaties and treaty practice

European Union

  • MiFID II and third countries: how far does the legislation reach?

France

  • Register of ultimate beneficial owners: a device of which terms remain to be finalized
  • End of the voluntary disclosure program in France from 1 January 2018

Hong Kong

  • Hong Kong's new apology law and its implications for financial institutions

Hungary

  • Hungary to increase statutory limitation period for corruption

International

  • Survey of beneficial ownership disclosure in Hong Kong, Singapore, Switzerland, and the UK

The Netherlands

  • Repeal of the Dutch Voluntary Disclosure Procedure

Russia

  • Conditions for and Implications on the Automatic Information Exchange with Russia

South Africa

  • Taxpayers beware: only lawyers can keep your secrets

Spain

  • Spain approves new international tax form for declaring related transactions and other situations involving tax havens

Turkey

  • Turkish Ministry of Finance announces new tax rate increases

United Kingdom

  • UK Budget overview: new taxes target tech companies and offshore property owners
  • Autumn Budget 2017 - No major changes to share plans but…
  • Budget 2017: Significant changes to UK taxation specifically affecting individuals
  • New tax charge for non-residents on UK real estate gains from 2019
  • The Trust Beneficial Owner Register: New Obligations for Trustees

United States

  • IRS announces new compliance programs targeting international taxpayers and financial institutions
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