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The Canada Revenue Agency (CRA, or the minister) has broad powers to audit and assess Canadian taxpayers, which leads to a variety of disputes in the courts.

This was Malusi Gigaba’s final budget, as he was replaced by Nhlanhla Nene shortly after delivering it Years of budget misuse have created a deep hole in South African government coffers. A new president means a new direction, starting with the 2018 budget that proposes a number of revenue-raising measures that are receiving mixed reactions.

Businesses love certainty. It allows them to plan and act on short, medium, and long-term strategies. The unexpected brings operational complexities they do not need. Recently, as taxation of the digital economy gathers pace it is a case of ‘expect the unexpected’ for digital businesses operating globally. Taxamo’s Iman Deschâtres and JP McCarthy explore the topic.

The Federal Commissioner of Taxation has appealed against the decision in the RCF IV case (Resource Capital Fund IV LP v FCT [2018] FCA 41). In that case, the Federal Court had held that the gains derived by two private equity funds, which were Cayman Islands limited partnerships, from the sale of shares in an Australian mining company were not subject to Australian income tax, on the basis that the Australia-US double tax treaty applied in respect of the US tax resident limited partners of the funds to exempt the gains from Australian taxation.

In November 2017, the European Court of Justice (ECJ) released its much anticipated decision in the case C-246/16 (Enzo di Maura). The case related to the right of an Italian taxpayer to reduce the amount of his VATable amount and thus the respective VAT, due to the fact that his customer (debtor) had declared bankruptcy. The court ruled that a member state could not reduce the VATable amount in the event of total or partial non-payment on the basis that insolvency proceedings had been unsuccessful, when such proceedings could last longer than 10 years.

Doug O’Donnell, head of the large business and international (LB&I) department in the IRS, speaks to Joe Stanley-Smith about how he runs his large business and international department in the rapidly changing arenas of US and international tax.

In recent years, the idea that offshore tax liabilities can easily be concealed from government revenue collectors has become a moribund concept. Huge data leaks increased international co-operation and developments such as FATCA and the global common reporting standard (CRS) have resulted in a situation where a person’s cross-border tax affairs are no longer fully secret.

On February 21 2018, the Ministry of Economy and Finance (MEF) released draft regulations for public consultation designed to provide operational guidance on transfer pricing. Following the international evolution that occurred at the OECD level, particularly with the BEPS project, a working group composed of the Finance Department, the Revenue Agency and the tax police have prepared an action plan aimed at implementing the legislation, providing clarity to taxpayers on basic principles and ensuring adequate training on the structures responsible for applying these rules.

As the United Kingdom hastily prepares for its planned exit from the EU, thereby leaving EU27 Member States (EU27), interesting trends are starting to develop for this change.

This year has been so busy thus far that it came as a surprise to me, when putting together this issue of International Tax Review, to realise that it was almost April, and that we're nearly a third of the way through the year.