Income tax treaties can provide significant protections for European investors and businesses in the US. As Congress seeks to close tax loopholes, to generate additional revenue, users of US tax treaties may face even tighter anti-treaty-shopping rules, warn Alfred Groff, Kristen Garry and Nathan Tasso, of Shearman & Sterling.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
They also warned against an ‘unnecessary duplication of efforts’ in UN tax convention negotiations; in other news, White & Case has hired Freshfields’ former French tax head
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
The Brazilian law firm partner warns against going independent too early, considers the weight of political pressure, and tells ITR what makes tax cool