International Tax Report

There is a fine line between effective tax planning that takes advantage of current regulatory and legislative allowances, and schemes that are perceived as ‘aggressive’ in the current anti-avoidance climate. George Arghyrakis discusses..

Andrew Howard comments on two recent First-tier Tribunal decisions and their potential implications for UK taxpayers. During the second week of August two decisions of the First-tier Tribunal were released[1], which illustrate the difficulties..

In Part I, Flavia Cavalcanti Pepe and H. David Rosenbloom introduced the concept of the derivative benefits provision and related tax policy issues. Here, they continue this discussion with an exploration of the technical issues, with some working..

Financial contracts such as derivatives, repurchase agreements and securities lending transactions serve vital functions for financial institutions as they facilitate risk management and provide liquidity. The agreements may provide for rights to..

Adam Blakemore, Catherine Richardson and Amy Faraday consider the detail of the OECD’s Final Report on Action 6 of the BEPS project, including analysis of its stance on tax treaty abuse, the LOB provisions and interaction with EU law. The..