Podcast Episodes
Back to Search
CRS Commentary on Financial Institutions Holding Equity Interests
Episode 1873
This episode examines a pivotal provision in the CRS Commentary—paragraph 178 (Section VIII, C(4))—and its implications for trusts that qualify as Re…
8 months, 1 week ago
CRS Treatment of Financial Institutions as Equity Interest Holders
Episode 1872
This episode examines a core structural rule of the Common Reporting Standard (CRS):
Financial Institutions are non-reportable persons and must not b…
8 months, 1 week ago
Where Switzerland Misinterpreted the CRS Implementation Handbook
Episode 1871
This episode examines a narrow but consequential interpretative issue:
Did Switzerland extend the CRS look-through rules for FI-trusts beyond what th…
8 months, 1 week ago
The Core CRS / FATCA Principle: No Look-Through of Financial Institutions
Episode 1870
The Core CRS / FATCA Principle: No Look-Through of Financial Institutions
At the heart of both CRS and FATCA lies a fundamental architectural rule:
Fi…
8 months, 1 week ago
How Switzerland Misapplied CRS Look-Through Rules for Trusts
Episode 1869
In this episode, we examine a controversial development in Swiss CRS practice: the extension of look-through obligations for trusts that qualify as R…
8 months, 1 week ago
Who Is An Equity Interest Holder Of A Trust Qualifying As A Reporting FI
Episode 1868
Understanding who counts as an equity interest holder is central to how the Common Reporting Standard (CRS) operates for trusts that qualify as Repor…
8 months, 2 weeks ago
When Absence Doesn’t Break Residency
Episode 1867
Leaving a country does not automatically mean you stop being a tax resident. In this episode, we explain why tax residency is a legal status, not a t…
8 months, 2 weeks ago
Advice for Tax Advisors Going Forward
Episode 1866
As global tax enforcement intensifies and private wealth comes under greater scrutiny, the role of the tax advisor is evolving fast. In this episode,…
8 months, 2 weeks ago
Advising High-Net-Worth Individuals
Episode 1865
As global tax policy shifts toward greater scrutiny of private wealth, advising high-net-worth individuals with international assets requires a funda…
8 months, 2 weeks ago
The Future of Taxation's Pillar Three
Episode 1864
Beyond Pillar One and Pillar Two, a new concept is beginning to surface in global tax policy discussions: an informal “Pillar Three”—focused not on m…
8 months, 2 weeks ago