September/October 2018  
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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. 5 - 2018 of the Derivatives & Financial Instruments is now available online.

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Number 5 - 2018 contains the following:
ARTICLES
United States

Introduction to the US Tax Reform Act

Paul Carman

This article deals with several changes on US taxation of financial instruments under the US TCJA. The changes include the introduction of a new interest barrier, a limitation on the deductibility of payments on hybrid instruments or in hybrid transactions, an excise tax on base erosion payments, a new system of allowing a deduction for distributions from non-US subsidiaries and changes in the US controlled foreign corporation rules.

United States

US Regulatory Framework for Cryptocurrency Transactions

Aleksandra Bal

This article describes the current cryptocurrency regulatory landscape in the United States. It focuses on the following areas: anti-money laundering, securities trading and taxation.

Korea (Rep.)

Korea’s Recent International Tax Reform Plan

Kyung Geun Lee

The article provides a summary of the key amendments proposed by the 2018 Korean Tax Amendment Package that may give a significant impact on international transactions or investments into or from South Korea.

Finland

Taxation of Non-Resident Institutional Investors in Finland – Recent Case Law and Developments

Tomi Vittala and Emmiliina Kujanpää

The Finnish tax provisions applicable to dividends and other investment income paid to non-resident institutional investors, particularly investment funds, pension funds and life assurance companies, are widely incompatible with EU law. In recent years the Finnish courts have issued several decisions on full or partial tax exemption granted to foreign institutional investors based on the free movement of capital and freedom of establishment provided by EU law, while the tax legislator has remained rather passive. This article examines the current tax practice based on the case law and discusses the problems relating to legal certainty due to various interpretations.

United Kingdom

VAT Impact of Brexit for Customers in the Financial Services Industry

Jochum Zutt

This article deals with the VAT changes that recipients of financial services, such as investors, holding companies and funds, face after Brexit.

Australia

Developments in Australian Anti-Hybrid Legislation

Anton Joseph

This article discusses the new Australian legislation on hybrid mismatch arrangements passed into law in August 2018. Closely modeled on the OECD recommendations, the amendments aim to achieve much more than what was initially envisaged.

International

GATCA: A 2018 Update to the Globalization of Anti-Tax Evasion Frameworks

Ross McGill

In his 2016 article, the author set the scene for Global Account Tax Compliance Activities (GATCA). These compliance activities share many common elements, foremost amongst which is their purpose: the global fight against tax evasion. However, while they share a general purpose, the methodology by which these frameworks are implemented varies according to the framework, and also the jurisdiction that is implementing them.

INTERNATIONAL TAXATION OF FINANCIAL INSTRUMENTS
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