Andrew Owen and Marc Schwartz have been invited to speak at the American Association of Attorney-Certified Public Accountants 47th Annual Meeting and Education Conference in Albuquerque, New Mexico on June 24, 2010. Our two representatives will be speaking on international tax issues impacting U.S. persons going abroad and U.S. taxation of non-residents. The June 22-27 [...]

By Paul Tadros and Marc Schwartz
This article first appeared in Financier Worldwide’s August 2009 Issue
In May, 2009, the President of the US issued his revenue proposals for the fiscal year 2010 (‘2010 Proposals’). This article addresses one of the more critical ones: reform of the business entity classification rules (commonly referred to as ‘check-the-box’ rules [...]

This article was originally published in Spanish in Analisis Tributario, Peru by Paul Tadros in 2004 and has not been updated for any subsequent changes. All rights reserved©.
INTRODUCTION
Peru, like most countries in South America, has immense economic potential which could reap substantial benefits to its people. This growth potential is maximized when foreign investment is [...]

8/20/2009 – This article, by Paul Tadros, was originally published in Tax Notes International by Tax Analysts and has not been updated for any subsequent changes. All rights reserved©.
INTRODUCTION
On July 14, 2004, Barbados and the US signed the second Protocol to the 1984 Income Tax Treaty (“treaty”). There are two (2) significant changes arising from [...]

(EMPRESA MULTINACIONAL ANDINA – “EMA”)
This article, by Paul Tadros, was originally published in Practical Latin American Tax Strategies by WorldTrade Executive Inc. and has not been updated for any subsequent changes. All rights reserved©.
INTRODUCTION
The EMA regime is akin to a holding company regime and is found only in the laws of Bolivia, Colombia, Ecuador, Peru, [...]

This article, by Paul Tadros, was originally published in Practical Latin American Tax Strategies by WorldTrade Executive Inc. and has not been updated for any subsequent changes. All rights reserved©.
Introduction
This article addresses a potential adverse risk inherent in Chile’s holding company regime (“regime”). Assuming that such holding company meets all of the requirements, Chile’s income [...]

This article, by Paul Tadros, was originally published in Practical Latin American Tax Strategies by WorldTrade Executive Inc. and has not been updated for any subsequent changes. All rights reserved©.
Introduction
In 2001, Luxembourg and Trinidad and Tobago (“Trinidad”) signed a double taxation agreement (“treaty”) covering both income and capital. The treaty became effective January 1, 2004. [...]

Mexico Thin Capitalization Update
BY MARC SCHWARTZ (SCHWARTZ ADVISORY SERVICES, INC.) AND JOSÈ JUAN MIRANDA (MIRANDA, SANCHEZ & ASOCIADOS)
Mexico’s 3:1 thin capitalization law has been a topic for debate in the Mexican and international tax community since its incorporation into the Mexican Income Tax Law (“MITL”) as of January 1, 2005. Businesses and those in the [...]

Potential Issues for Mexican Tax Reform Debate
By Marc Schwartz (Schwartz Advisory Services, Inc) and José Juan Miranda (M&V Asociados)
Each year the annual budget the Mexican Congress approves for the following year generally contains amendments to various tax laws.
Since becoming President, Vicente Fox has introduced significant tax reform proposals that have for the most part been [...]

Uruguayan Free Trade Zones
BY JONAS BERGSTEIN (ESTUDIO BERGSTEIN) AND MARC SCHWARTZ (SCHWARTZ ADVISORY SERVICES, INC.)
Uruguay’s Free Trade Zones have grown significantly over the past decade and now boast the participation of several multinational companies such as IBM, Hewlett-Packard, Fisher-Price, Merrill Lynch and Tata Consulting.
Uruguayan Free Trade Zones serve as a growing trading hub in the [...]