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Feature

United States

  • The Circuit Court reins in jurisdiction over foreign banks  

Case Summaries

European Union

  • European Court of Justice provides clarifications on concept of "wholly artificial arrangements" in joined cases Deister Holding (C-504/16) and Juhler Holding (C-613/16)

Germany

  • Forced heirship entitlement of a grandchild

United Kingdom

  • HMRC follows up on Rangers case

United States

  • Outside of the Safe Harbor for Reverse Like-Kind Exchanges, the IRS intends benefits and burdens to reign
  • Failure to use proration method does not always violate normalization rules
  • Transfers of foreign goodwill and going concern value: Treasury considers a limited active trade or business exception

Legislative Developments

Argentina

  • Corporate criminal liability law for corruption offenses is in force
  • Amendment to tax on credits and debits on bank accounts
  • Tax and social security reforms – impact on employment matters

Australia

  • NSW surcharge purchaser duty and surcharge land tax

Brazil

  • Simplified rules for offsetting income tax paid and modifications to list of low tax jurisdictions and privileged tax regimes

Canada

  • CRA position on equity compensation

China

  • China revives tax incentive for dividends reinvested into China

Colombia

  • Tax Office's current position on foreign trusts vis-à-vis normalization tax

European Union

  • EU Parliament's Panama Papers Committee issues report and accuses EU Member States of being part of the problem

International

  • The unintended consequences of taxing the digital economy

Luxembourg

  • New circular on taxation of stock options
  • New Luxembourg Tax Circular on Residency Certificates Issuance for UCIs (now includes RAIFs)

Malaysia

  • Highlights of the Malaysian Budget 2018

Philippines

  • The TRAIN Law and wealth management

Peru

  • OECD member countries no longer considered tax havens for Peruvian income tax purposes from 1 January 2019

South Africa

  • Enquiry into South African Revenue Service under collection

Spain

  • Spanish Tax and Customs Control Plan Guidelines for FY 2018 approved
  • New criteria in Spain to establish tax residency

Switzerland

  • The Swiss Federal Supreme Court enjoins the Swiss Tax Administration from providing names of bank employees and other third parties to the IRS

Turkey

  • Significant amendments to Turkish tax legislation
  • Interest-free finance will be regulated separately in Turkey

United States

  • The Good, the Bad and the GILTI – ten takeaways from US tax reform for high net worth individuals
  • Tax reform in Congress gives way to implementation and additional questions
  • Congress reforms system to make United States more competitive through reduced rates, immediate expensing, shift to territorial system, and the IP carrot (and stick)
  • Passthrough tax changes under the Tax Cuts and Jobs Act
  • EU considers impact of US tax reform
  • IRS issues repatriation tax guidance under new law
  • Impact of tax reform on real estate
  • Provisions of US tax reform impacting the renewable energy industry
  • Provisions of US tax reform impacting private equity
  • IRS releases notice on US passport revocation and limitation process
  • End of OVDP

Venezuela

  • New Venezuelan income tax - 32,000 tax units exoneration for resident individuals with respect to fiscal year 2017
  • Venezuelan income tax exoneration for holders of bonds issued by BANDES
  • New rules on contributions and fees to be paid by individuals to the National Office of the Superintendent of Securities
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