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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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