In last month’s article, the authors discussed the tricky question of what constitutes a QI and recently issued guidance by the IRS. Part two of this article answers frequently asked questions about the day-to-day application of the QI rules and addresses the need not to be complacent, By Philip Marcovici and Marnin Michaels of Baker & McKenzie’s Zurich office, Thomas O’Donnell in the Paris office and David Balaban and Peter Connors of Baker & McKenzie in New York
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort