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Reform of the U.S. Tax Regime – The Swiss Perspective

Published by Prager Dreifuss, Tax Newsletter (February 2018).

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Insights Vol. 5 No. 1: Updates & Tidbits

Insights Vol. 5 No. 1: Updates & Tidbits

This month, Neha Rastogi and Nina Krauthamer look briefly at three recent developments in international tax: (i) expired I.T.I.N.’s and how tax returns that use an expired I.T.I.N. will be treated by the I.R.S., (ii) the E.U. blacklist of uncooperative jurisdictions, which includes American Samoa and Guam, and (iii) and unanticipated tax demands on contributions to the Brexit campaign.

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Income Shifting: Common Ownership or Control Under Code §482 in an Inbound Transaction

Income Shifting: Common Ownership or Control Under Code §482 in an Inbound Transaction

The Large Business and International Division of the I.R.S. (“LB&I”) periodically develops international practice units (“I.P.U.’s”) that serve as training material for international examiners.  In November 2017, an I.P.U. entitled “Common Ownership or Control Under IRC 482 – Inbound” was published.  On the same date, the I.R.S. issued a sister I.P.U. for outbound transactions, “Common Ownership or Control Under IRC 482 – Outbound.”  Together, they serve as a primer for determining whether sufficient control exists between two parties to bring the arm’s length transfer pricing rules of Code §482 into play.  Stanley C. Ruchelman explains how the I.R.S. trains its examiners when determining whether a transfer pricing adjustment is appropriate. 

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Individual, Corporate, and Trust News from France

Individual, Corporate, and Trust News from France

The end of each year in France is marked by a fiscal legislative process to amend the current year’s finance law and to draft the law for the upcoming year.  The year 2017 was no exception.  Changes will be made to wealth tax, tax brackets, tax on investment income, corporate tax rates, and the 3% additional tax on dividend distributions (retroactively).  Fanny Karaman and Nina Krauthamer explain the tax changes.

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Circular Letter No. 25/E Clarifies Italy’s New Carried Interest Regime

Circular Letter No. 25/E Clarifies Italy’s New Carried Interest Regime

Early last year, the Italian government announced new rules regarding favorable taxation of carried interests.  Graduated tax rates and social charges would be replaced by a flat 26% tax on investment income.  Towards the end of the year, guidelines were published by the Italian tax authorities providing significant clarifications on the scope, requirements, and conditions under the new tax regime.  Andrea Tavecchio and Riccardo Barone of Tavecchio Caldara & Associati, Milan, examine how the new regime will work in practice.

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