Netherlands: The Netherlands To Expand Its Fiscal Unity Regime To Second-Tier Subsidiaries And Sister Companies Following EU Court Of Justice Ruling

On June 12, 2014, the EU Court of Justice (“ECJ”) ruled in two joint cases that the Dutch fiscal unity regime infringes on the EU freedom of establishment, because it does not allow a fiscal unity between (i) a Dutch resident parent company and its second-tier Dutch resident subsidiary held through an EU resident intermediate company, or (ii) two Dutch resident sister companies held by the same EU shareholder. The ECJ further ruled that […]

By |October 10th, 2014|

A Tax Year In Review: Canada, US And Cross-Border – October 22, 2014

Complimentary seminar presented by: Moodys Gartner Tax Law and Wealthy Tortoise Financial Group

Date: Wednesday, October 22, 2014
Time: morning session – 9:00 am – 12:00 pm or afternoon session – 2:00 pm – 5:00 pm
Location: Hotel Eldorado, 500 Cook Road, Kelowna BC
Registration: wtadmin@wealthytortoise.ca or 1.250.717.8800

A 2014 tax year in review for Canada, US and cross-border professional tax practitioners, lawyers and accountants with private clients that require Canadian and US tax advice.

Registration fee will be accepted […]

By |October 9th, 2014|

Worldwide: OECD Releases First BEPS Recommendations To G20 In Accordance With Action Plan

As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the “Action Plan”) and consist of the following items:

Recommendations for domestic rules to neutralize hybrid mismatch arrangements and recommended changes to the OECD Model Tax […]

By |October 9th, 2014|