Importance of legal certainty in cross-border scenarios
In the context of the EU VAT system, the principle of legal certainty requires that Community legislation must be certain and its application…
The FFI GIIN List Update (Lists from June 1, 2014 through June 1, 2015)
On 1 June 2015 the IRS published its thirteenth FATCA GIIN list of “approved FFIs” (a list of the financial firms that have…
Co-authored by Luís Eduardo Schoueri and Mateus Calicchio Barbosa
Spotlight was shed on transparency by the OECD’s BEPS Plan, where a set of Actions was put forward under the flag of “ensuring…
Dr. Andrew Morriss, Dean of Texas A&M University School of Law
The rapidly shifting world of international financial and tax regulation – from the OECD’s BEPS to FATCA – is reshaping the world.…
1. FBAR Filing Requirement
The FBAR refers to Form 114, Report of Foreign Bank and Financial Accounts. The FBAR must be filed annually by a U.S. person that has a financial interest in or signature…
Three significant filing deadlines fall in June, one today and two more on the last day of the month.
(1) The 15 June FATCA Form 8938 filing deadline (with the income tax return) with the IRS for a U…
Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is,…
BEPS-Project? CFC rules and transfer pricing? Treaty abuse and dispute resolution? Why bother for such complicated things? Greece has a “perfect” solution against base erosion and profit shifting…
Action 6 of the BEPS Action plan is aimed at (i) developing Model Treaty provisions and recommendations on the design of domestic tax rules to prevent the granting of treaty benefit in inappropriate…
Along the last 15 years, the discussion of tax planning in Brazil evolved significantly, changing from a very formalist approach to an approach that scares taxpayers by its aggressiveness and lack of…
