David Forst and James Fuller of Fenwick & West analyse recent international tax developments, covering foreign tax credits, foreign tax structured transactions, passive foreign investment companies and exchange-traded notes, that are potentially of interest to financial service industry participants in capital markets
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap