Due to an amendment of the EU Parent-Subsidiary Directive, the EU Member States must include a common minimum anti-abuse provision in their legislation by 31 December 2015 at the latest.
The common…
This week, the United Kingdom Supreme Court, in a landmark decision, has ruled that a UK resident individual member of a Delaware limited liability company is entitled to credit in the UK for US tax…
International theory and practice
In examining the economic considerations that should be taken into account for the legal framework for the eventual peace agreements in Colombia, I found that…
Co-authored with Hans van den Hurk, Maastricht University, QuanteraGlobal Tax Policy. Note that the authors write in their personal capacity.
Policymakers are changing the international tax system to…
0n June 17 2015, the Commission re-launched the CCCTB Directive after being four years discussions in the Council of the European Union. In 2016 the Commission will issue a completely new CCCTB…
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…
