Traditionally, EU Member States have restricted charitable tax reliefs to domestic charities meaning that a legacy to a foreign charity may attract a tax liability. However, the European Court of Justice has established a general principle of non-discrimination in line with the free movement of capital.

As many UK charities will know, theory and practice with regard to the application of non-discrimination in France have not always been aligned. French domestic law previously granted tax […]

On February 2, 2015 the Obama Administration acknowledged the plight of certain US citizens residing abroad and proposed limited relief. In the “General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals”1, known as the “Green Book,” the Administration proposed a change to US law (the “Proposal”) that would allow certain dual citizens to renounce their US citizenship without the fear of delinquent tax filings, penalties, the US exit tax, and the other consequences to […]