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Feature

  • Wegbreit: A cautionary tale for trustees, lawyers and wealth owners

Case Summaries

France

  • Management share schemes: Details on the requalification of capital gains as wages

Hong Kong

  • Wong, Choy and the capacity checklist

United States

  • In Flume, the taxpayer's inconsistent and disingenuous testimony leads to willful FBAR penalty
  • IRS concedes position on creditability of French social charges
  • North Carolina unable to tax a trust's income based solely on the residency of in-state beneficiaries

Legislative Developments

Italy

  • Amendments to special tax regimes for incoming residents

Mexico

  • Anti-money laundering regularization program

Netherlands

  • Netherlands government publishes legislative proposal implementing EU rules on mandatory disclosure of 'potentially aggressive' cross-border tax arrangements (DAC6 Directive)
  •  Relaxation of Dutch visa and wage tax rules for start-ups

Russia

  • Third round of the Russian voluntary disclosure program
  • Liberalization of currency control regulations

Spain

  • Ever closer to entry into force of Protocol amending the Treaty between Spain and the United States to avoid international double taxation
  • Spanish General Directorate of Taxes extends the application of the Autonomous Communities legislation re: Inheritance and Gift Taxes to individuals residing in non-EU/EEA countries

Taiwan

  • Update on new Tax Code in Taiwan to encourage funds repatriation

Turkey

  • Turkey's new asset peace initiative

United States

  • IRS begins notifying owners of cryptocurrency of potential failures to report income and pay taxes
  • IRS releases proposed regulations for foreign partner effectively connected income and withholding
  • IRS and State Department set to issue passport revocation notices (Letter 6152)

Venezuela

  • Venezuelan National Constituent Assembly approves a new tax of 0.25% on high net worth
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