The new U.S. FATCA legislation and implementing inter governmental agreements granting reciprocal and automatic exchange of financial information between tax administrations will make international tax reporting and compliance mandatory and unavoidable, and will tax authorities with formidable tools for international audits and enforcement activities.
Continue Reading Reciprocal Inter Governmental Agreement Will Introduce Automatic and Reciprocal US-Italy Disclosure and Exchange of Information For Tax Purposes

Italy’s tax administration published its report on Italian international tax ruling showing 52 applications and 19 agreements signed in the first five years of the program, half of which by foreign multinational enterprises.
Continue Reading Italy’s Tax Administration Published Report on Italian International Tax Ruling (APA)

New law targets the use of sale and repurchase agreements and securities lending transactions for tax advantages. According to the new law, the repo buyer or borrower in a securities lending transaction is eligible for tax benefits such as credits for withholding taxes or foreign taxes or participation exemption for dividends on stock, only if and to the extent those benefits could be attributed to the repo seller or securities lender. The new provision is aimed at stopping transaction such as dividend washing or dividend stripping, in which the a holder of securities who would not be eligible for certain tax benefits, transfer those securities to an accommodating party, who collects the benefits, in exchange for an equivalent economic consideration.
Continue Reading New Law Targets Tax Abuse of Repos, Securities Lending Transactions