HLB Gross Collins, P.C.’s Post

A recent Italian tax reform has offered optional penalty protection against anti-hybrid rule assessments starting from 2020 🇮🇹 By preparing specific documentation and notifying authorities, companies can avoid hefty administrative penalties between 90-180% and potentially benefit in criminal tax matters. Guido Arie Petraroli, Francesco Cardone, Erminia Procopio, Luca Galliani, and Francesco Murgo from Alma LED analyse this reform in more detail. Click the link commented below to read more 🔗 #Tax #TaxReform #Italy

Great article on what taxpayers that have remitted Section 965 transition tax payments should keep in mind in case of a taxpayer-favorable decision. 

PwC's Cross-border tax talks: "Moore v. US: Constitutionality of international tax"(28.45)... Discussion of the upcoming US Supreme Court case (Moore v. US) on whether section 965 (i.e., TCJA's transition tax) breaches the 16th Amendment of the US Constitution, including: (1) Legal background - (a) To avoid the 16th Amendment's requirement for direct taxes to be apportioned among the States, a direct tax needs to be on "income" - does "income" have a realization requirement? (b) Is Eisner v Macomber still good law? (2) Potential collateral damage if taxpayers win - GILTI, Subpart F, mark to market taxation, GloBE rules? (3) How could Supreme Court limit the consequences? Doug McHoney Wade Sutton #internationaltax #US #Moore #PwC

Many taxpayers are still facing the complexities of the transition tax under IRC section 965, also known as the Mandatory Repatriation Tax (MRT). Rita Ryan, International Tax Services Lead at Wolf & Company, P.C., delves into the details of this tax and the ongoing Supreme Court case challenging its constitutionality. #cpa #accounting #cpe #tax #internationaltax

Just published the first version of the Guide on the special tax regime for expats moving to #Spain (the so-called Beckham Law), allowing to exempt passive foreign income from taxes for six years. #BeckhamLaw #ExpatTax #Spanishtax #taxplanning

Crowell & Moring’s Carina Federico comments on the Foreign Account Tax Compliance Act and the possibility for an increase in enforcement activity. Read more in Tax Notes:

Crowell & Moring’s Carina Federico comments on the Foreign Account Tax Compliance Act and the possibility for an increase in enforcement activity. Read more in Tax Notes:

Crowell & Moring’s Carina Federico comments on the Foreign Account Tax Compliance Act and the possibility for an increase in enforcement activity. Read more in Tax Notes:

Italy introduces legislative decrees such as the International Tax, Tax Ruling, Tax Controversy, and Cooperative Compliance decrees, alongside the Income Tax and 2024 Budget Law, bringing significant changes to corporate and individual taxation.📊📜🌐 #italy #tax #internationaltax #corporatetax #incometax #taxreform #policy

ITR | Italy clarifies natural persons’ tax residency qualification under tax treaties Paolo Ludovici and Ludovica Lorenzetto on ITR (International Tax Review) report that the Italian Supreme Court has ruled that a natural person does not need to be actually subject to individual income tax to receive tax treaty protection. Read the article:https://lnkd.in/dbBKK4EQ    #tax #taxpolicy #internationaltax #directtax #withholdingtax #taxresidency #italytax #Internationaltaxreview #GPBL