	How FATCA Will Affect Every Business Making Cross-Border Payments - May 2013 United States taxpayers should be aware that, beginning in 2014, cross-border payments are generally subject to additional reporting obligations under the Foreign Account Tax Compliance Act (“FATCA”). Whether it is a dividend or interest payment to a [...] Read More
	Expatriate Tax Update - April 2013 This newsletter brings together individual country updates over recent months. As you will appreciate, the wealth of changes across multiple jurisdictions is significant so to provide easily digestible information we have kept it to the key developments [...] Read More
	The American Taxpayer Relief Act of 2012 Extends Favorable International Tax Provisions - February 2013 On January 1, 2013, Congress passed the American Taxpayer Relief Act of 2012, which the President quickly signed into law on January 2, 2013. The Act extends a host of expired and expiring tax breaks for [...] Read More
	Exposure Draft Law Introducing New Australian Transfer Pricing Rules - January 2013 On November 22, 2012, the Australian Government released for consultation an exposure draft law of proposed amendments to reform Australia’s transfer pricing rules. The proposed amendments will [...] Read More
	New Streamlined Filing Procedures Announced by IRS for U.S. Citizens Living Abroad - November 2012 The United States of America is one of the few countries in the world that subject their citizens to taxation when such citizens are resident in other countries. For many of such United States citizens abroad, there is [...] Read More
	United Kingdom Budget Released - May 2012 On March 21, 2012, the United Kingdom government released its 2012 Budget proposals. The proposals require parliamentary approval and Royal Assent before they are enacted into law. [...] Read More
	Expatriate Tax Update - May 2012 This newsletter brings together individual country updates over recent months. As you will appreciate, the wealth of changes across multiple jurisdictions is significant so to provide easily digestible information we have kept it to the key developments [...] Read More
	Foreign Financial Account Reporting Regulations Issued In Final Form: Signature Authority Addressed - March 2012 The Treasury Department Financial Crimes Enforcement Network (FinCen) last week issued final regulations clarifying which persons are required to file reports of financial accounts under federal banking law. [...] Read More
	IRS Releases Proposed FATCA Regulations - March 2012 With the release of the proposed regulations for publication in the Federal Register (REG-121647-10), the Treasury Department has now provided important guidance regarding FATCA. The following is a brief overview [...] Read More
	Expatriate Tax Update - February 2012 This newsletter brings together individual country updates over recent months. As you will appreciate, the wealth of changes across multiple jurisdictions is significant so to provide easily digestible information we have kept it to the key developments [...] Read More
	Expatriate Tax Update - November 2011 This update brings together individual country updates over recent months. As you will appreciate, the wealth of changes across multiple jurisdictions is significant, so to provide easily digestible information, we have kept it to the key developments [...] Read More
	Potential to Extend Time for Making Submissions for the 2011 Offshore Voluntary Disclosure Initiative - July 2011 Affecting United States taxpayers who are looking to take advantage of the Offshore Voluntary Disclosure Initiative. [...] Read More
	IRS Issues Newly Revised Form TD F 90-22.1 for Foreign Bank and Financial Account Reporting - April 2011 Affecting any United States person who holds a financial interest in or has signature (or other) authority over a foreign bank or financial account. [...] Read More
	Opportunity for Penalty-Free Late Filings Under the 2011 Offshore Voluntary Disclosure Initiative - April 2011 Affecting United States taxpayers who have failed to file certain foreign information reporting forms but who have no unreported income from international activities [...] Read More
	Foreign Financial Account Reporting Regulations Issued in Final Form: Signature Authority Addressed - March 2011 Affecting any United States persons with control or signature authority over foreign bank and financial accounts. [...] Read More
	President Signs H.R. 1586 Containing International Tax Provisions - September 2010 On August 10, 2010, President Obama signed into law H.R. 1586 as Pub. L. No. 111-226 (the “Act”). Although the Act is popularly referred to as the Education [...] Read More
	French Supreme Court Imposes Laws Regarding Stock Option Income - August 2010 After many years of litigation regarding the sourcing of stock option gains of mobile employees, the French Supreme Court issued a ruling that provides definitive [...] Read More
	New Law Expands Limitations Period With Respect To The Failure To Report Certain Foreign Activities - May 2010 Section 513(c) of the Hiring Incentives to Restore Employment (“HIRE”) Act provides that the three-year [...] Read More
	French Supreme Court Issues Ruling On Commissionaire Structures And The Creation Of French Permanent Establishments - May 2010 On March 31, 2010, the French Supreme Court released its opinion in the Zimmer Ltd. case. The opinion was important for many international businesses that use [...] Read More
	China Insider - April 2010 The tax political measures of the Chinese government and the financial administration obviously reflect that China can no longer be considered as a low tax country. An essential part of the latest tax decrees and [...] Read More
	Chinese Tax Authority Now Require Transfer Pricing Documentation - April 2010 On January 8, 2009, the Chinese State Administration of Taxation (“SAT”) released national transfer pricing documentation guidelines contained in the Implementation Rules for Special Tax Adjustments [...] Read More
	Chinese Tax Authority Targets Foreign Businesses in China - April 2010 On February 20, 2010 the Chinese State Administration of Taxation (“SAT”) issued Guoshuifa [2010] No. 19 (“Circular 19”), which provides new guidelines for the application [...] Read More
	U.S. Tax Court Decision on Xilinx - April 2010 On March 22, 2010, the United States Court of Appeals for the Ninth Circuit reversed its previously withdrawn opinion in the Xilinx case, deciding this time in favor of the taxpayer.In the original tax dispute, the Internal [...] Read More
	Obama Administration Outlines New Proposals to Reform International Tax Provisions and to Strengthen Enforcement of Offshore Tax Disclosures - March 2010 On February 1, 2010, the Treasury Department released General Explanations of the Administration’s Fiscal Year [...] Read More
	New Protocol to United States - France Income Tax Treaty Enters Into Force Creating Possible Refund Opportunity for Certain Dividend and Royalty Payments - March 2010 A potential refund opportunity exists for excess withholding tax on dividends and royalties as a result [...] Read More
	United States-Italy Income Tax Treaty Enters Into Force - March 2010 On December 16, 2009, the United States Treasury Department announced that representatives of the United States and Italy completed the exchange of [...] Read More
	Tax Court Rules Against IRS in Veritas Software Corp Cost-Sharing Trial - February 2010 On December 10, 2009, the United States Tax Court ruled in favor of VERITAS Software Corp. (“VERITAS U.S.”) in its case against the Internal Revenue Service, stating [...] Read More
	Tax Court of Canada Rules in Favor of GE Capital Canada in Guarantee Fee Trial - February 2010 On December 4, 2009, the Tax Court of Canada decided in favor of General Electric Capital Canada Inc. (“GE Capital Canada”) in General Electric Capital Canada Inc. v. Her Majesty The Queen, a case related to the [...] Read More
	Mexican Tax Reform of 2010 - December 2009 After Mexican President Calderon’s signature, the revenue provisions of the 2010 Mexican Budget were published in the Official Bulletin on November 25, 2009. With the publication, the tax reform package [...] Read More
	New Protocol Amending United States-Switzerland Income Tax - November 2009 The new protocol provides zero withholding tax on dividends paid to eligible IRAs and pension plans, new exchange of information, and mandatory [...] Read More
	Worldwide Tax News - August 2009 On May 11, 2009, the US Treasury Department released General Explanations of the Administration’s Fiscal Year 2010 Revenue Proposals (the ‘Green Book’), a document that provides a description of the Obama Administration’s budget proposals affecting [...] Read More
	Temporary Relaxation of German NOL Limitation and Interest Barrier Rules - August 2009 On June 19, 2009, the German Bundestag (Lower House) passed the Citizen Relief Act proposing some relief from the country's harsh loss limitation rules. [...] Read More
	United States and Hungary Agree on New Income Tax Treaty - August 2009 The United States Department of the Treasury and the Hungarian Finance Ministry agreed on a new income tax treaty with a comprehensive limitation on benefits ("LOB") provision. Read More