FATCA

High Court dismisses application concerning breach of data rights under FATCA.

Adam Rose

Filippo Noseda and Adam Rose (Mishcon de Reya) discuss the data protection repercussions of a system of automatic exchange of information in light of recent court decisions in the US and UK.

Matthew Mortimer

Kitty Swanson

Matthew Mortimer and Kitty Swanson (Mayer Brown) consider some important tax treatments that can apply to structured finance transactions.

Andrew Howard

How things have changed.

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.

Will Smith, Leonard Ng, Chris Brause, Stuart Pibworth

Will Smith, Leonard Ng, Chris Brause and Stuart Pibworth (Sidley Austin) review recent developments within the investment funds industry which faces numerous challenges in the form of UK and international tax initiatives, as well as ongoing regulatory change.

India and the Philippines have signed FATCA intergovernmental agreements (IGAs) with the US. Both IGAs are based on the model 1A IGA, and both jurisdictions have previously reached agreements in substance for a Model 1A IGA with the US.

Mark Middleditch

Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including UK FATCA rules in relation to holding and treasury companies; a FTT case on the assumption of debt on share sales; BEPS and the US proposals to combat treaty abuse; and the EU Commission’s action plan in relation to the new tax transparency package.

Andrey Krahmal

The definition of investment entities under FATCA, under the model IGA and under the UK IGA, regulations, guidance notes varies in important respects. Andrey Krahmal (Temple Tax Chambers) provides a summary of how the rules apply to investment entities most frequently encountered in practice.