International Tax Report

Kristin Konschnik and Maya Ladno analyse the proposed changes to the US Model Income Tax Treaty, with a particular focus on the limitation of benefits and expatriated entity provisions. On 20 May 2015, the US Treasury Department released..

This article, written by Siamak Mostafavi and Nicolas Andre, provides a broad overview of the French tax treatment of hybrid instruments, along with coverage of some specific anti-abuse provisions. French commercial law enables the issuance of..