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Derivatives & Financial Instruments
This free e-mail service informs you about the contents of the forthcoming edition of Derivatives & Financial Instruments.

Issue No. 3 - 2016 of the Derivatives & Financial Instruments is now available online.

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Number 3 - 2016 contains the following:
GATCA: The Globalization of Anti-Tax Evasion Frameworks
Ross McGill
The author brings clarity and order to the major challenges being faced by the financial services industry and its customers in light of GATCA – the globalization of anti-tax evasion measures.
No Substance Requirements for Belgian Notional Interest Deduction
Werner Huygen and Peter Vandenbussche
This article describes case law of the Antwerp Court of Appeal rendering a judgment that calls for a strict interpretation of the rules laid down in the Belgian tax code relating to the restriction of the notional interest deduction. The position of the tax authorities consisting in adding conditions to a set of clear legal provisions cannot be sustained. Legal restrictions to the notional interest deduction are to be interpreted strictly.
United States
New Rules Proposed for Debt-Equity Classification
Paul Carman
In April 2016, the US Treasury proposed new Regulations under section 385 of the Internal Revenue Code that are intended to govern the classification of instruments between related entities as debt or equity in a variety of circumstances. The author discusses the two aspects of the proposed Regulations that represent a significant change in direction compared to traditional US authorities on debt-equity classification.
French Foreign Tax Credit: A Clap of Thunder in a Calm Sky
Cyril Valentin and Benjamin Boisanté
Tax credits granted under French income tax treaties are generally limited to the “amount of French tax attributable to that income”. The common interpretation was that this amount corresponded to gross income multiplied by the standard tax rate. A recent decision of the Council of State (the supreme administrative court) marks an unfortunate turn for French recipients of foreign-source dividends.
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