We understand that an advisory firm must match top-quality technical interpretation with an understanding of the operational implications in order to deliver advice that can be implemented by the client efficiently and without undue disruption US.
US §864(c)(8) & §1446(f) RegulationsWithholding and reporting on non-US investors on payments from Private Equity and other funds holding active US companies |
OECD CRSAutomatic exchange of financial account information by banks and other financial intermediaries
US §871(m) RegulationsWithholding and reporting on non-US investors on payments from derivative instruments with underlying US equities |
CARF & DAC8Increased tax and regulation of digital assets, including incoming inclusion into reporting regimes per OECD's CARF and EU's DAC8
EU DAC6 & OECD MDRsDisclosure rules for service providers party to cross-border transactions displaying "aggressive" tax attributes |
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Other US International, Corporate, Trust & Partnership Tax Matters
A variety of tax advisory services focused on cross-border payment flows and asset holdings for US Persons and non-US Persons with US assets, including US income and estate taxation, with an eye on the current plans for a proposed global corporate tax minimum and the consequences in Switzerland and elsewhere from the 2017 and 2022 US tax reforms
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