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Introduction The Brazilian Ministry of Finance introduced before the G20 a proposal to establish a global minimum tax on ultra-high-net-worth individuals (UHNWIs). The initiative, supported by reports from the Addis Tax Initiative (ATI), the Tax Justice Network, and analyses from professional advisors, aims to ensure that extreme concentrations of wealth contribute fairly to global public finances. Summary of the Regulation The proposal seeks to impose a minimum tax burden o

Introduction The Full Federal Court of Australia, in Oracle Corporation Australia Pty Ltd v Commissioner of Taxation [2025] FCAFC 145 , overturned the Federal Court’s 2024 decision and granted Oracle a stay of domestic proceedings pending the completion of a Mutual Agreement Procedure (MAP) under the Australia–Ireland Double Tax Agreement (DTA). The dispute arose from payments made by Oracle Australia to Oracle Ireland between 2013 and 2018 for sublicence rights to computer s

Over the past three years, the number of U.S. citizens formally renouncing their nationality has climbed steadily, revealing a structural shift rather than a passing trend. According to the Federal Register’s Quarterly Publication of Individuals Who Have Chosen to Expatriate , 3,260 individuals were listed in 2023, 4,820 in 2024, and already 2,342 through mid-2025. If current trends persist, 2025 will register a significantly high expatriation count. This rise reflects an i

The United States Court of Appeals for the Eighth Circuit’s decision in 3M Company and Subsidiaries v. Commissioner of Internal Revenue (No. 23-3772, October 1, 2025), titled “Eighth Circuit Shields Blocked Income,” represents a pivotal development in international tax jurisprudence. The court reversed the Tax Court’s judgment that had upheld the IRS’s allocation of nearly $23.7 million in additional royalty income which Brazilian law prohibited 3M’s subsidiary from paying.

The Guardian reports a surge in U.S. citizens relocating to Europe following Donald Trump’s return to the presidency. From Barcelona to Dublin, Americans are seeking what they describe as political stability and personal safety. Visa applications to France and Ireland have increased significantly, while European institutions and local governments are launching initiatives to attract skilled U.S. nationals. From a migration perspective, this movement underscores a growing dem

In today's global economy, multinational corporations (MNCs) face unique challenges when it comes to pricing their goods and services...

Taxation is a complex and often contentious issue, especially when it crosses borders. For individuals and businesses operating...

Moving to a new country can be an exciting adventure. However, it also comes with its own set of challenges, especially when it comes to...