Exclusion of tax advantage on cross-border transactions
Jackie Wheaton (Moore Stephens) answers a query on a UK person investing in a US LLC that is tax transparent for US purposes
The OECD has announced that it will release its first recommendations for a coordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 base erosion and profit shifting (BEPS) project on Tuesday 16 September 2014.
The government of the Seychelles has agreed to the automatic sharing of tax information, becoming the latest of 46 countries and jurisdictions to make a commitment to implement the new OECD global standard, which will see the first exchange of information in 2017.
Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts
Chris Morgan (KPMG) summarises recent international tax news, including updates from India, China and Poland; the CJEU decision in the Nordea Bank Danmark A/S case in Denmark; and updates to the OECD Model Tax Convention
Martin Zetter (Macfarlanes) provides an update on the Amazon hearing in the US; plus transfer pricing news from India, Bolivia and Tanzania; and the OECD consultation on BEPS action 11
Can the trend for tax inversions survive an assault from the US Treasury department? Adam H Rosenzweig, professor of law at Washington University School of Law, assesses the situation.
FATCA affects the operations of most UK funds. Andrey Krahmal provides a summary
Jayne Newton takes a look at where we are now on the new ‘global FATCA’,