This discussion at the IBA Annual Conference Toronto 2025 looked at the explosive growth of global data generation, examining how rising AI workloads, hyperscaler expansion and power scarcity are reshaping the fundamentals of site selection, permitting, energy strategy and infrastructure planning.
Released on Feb 27, 2026
This article analyses the transformation of the tax adviser’s role in Mexico within a context characterised by intensified tax enforcement, technological oversight, judicial reform and evolving client expectations. It argues that the profession has evolved from being a predominantly technical function into a strategic, preventive, interdisciplinary and ethical practice, focused on risk management and legal certainty.
Released on Feb 27, 2026
This panel at the IBA Annual Conference in Toronto explored the tax implications of changing residency and how tax policy, politics and personal priorities drive mobility for internationally active families and entrepreneurs. The discussion covered, among other things, exit taxes and dual residency, permanent establishment (PE), controlled foreign corporation (CFC) regimes, new tax law developments and family and succession law issues. Against a backdrop of political volatility and regulatory change, the panel distilled practical guidance drawn from recent cases and experiences in the US, Mexico, France, Spain and Israel.
Released on Feb 24, 2026
This panel session at the IBA Annual Conference in Toronto included a discussion of considerations for inbound investments into Canadian resource companies, challenges associated with Canada’s foreign affiliate dumping regime, repatriation strategies and Canada’s unique flow-through share financing regime for early stage capital.
Released on Feb 24, 2026
This report provides a comprehensive overview of discussions on recent developments in international corporate taxation, focusing on the implementation of the Organisation for Economic C-operation and Development’s (OECD) Pillar Two rules, the emerging side-by-side system and related legal and transactional implications. It summarises the G7’s support for the use of a side-by-side approach, potentially exempting United States multinational enterprises (MNEs) from the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR), as well as providing updates on Pillar Two adoption and adjustments in Ireland, Canada, Switzerland, Latin America and the United Kingdom. This article also highlights practical considerations for cross-border transactions, securitisations and evolving tax insurance solutions.
Released on Feb 24, 2026
This panel session at the IBA Annual Conference in Toronto offered comprehensive analysis of the burgeoning global trend of digital nomads (DNs) and the complex legal and regulatory challenges they present both for individuals and employers. Spurred by the post-pandemic shift to remote working, the panel reviewed the rapid expansion and highly variable design of DN visa schemes worldwide.
Released on Feb 24, 2026
This panel at the IBA Annual Conference in Toronto explored the increasing relevance of non-judicial mechanisms in regard to resolving tax disputes and securing certainty at a time when audits are more complex, cross-border interactions more frequent, and judicial systems more strained.
Released on Feb 24, 2026
This is a report on a session that took place at the 24th Annual US and Europe Tax Practice Trends in Munich on 12 April 2024. The panel explored some of the most relevant tax issues stemming from cross-border work arrangements.
Released on Jan 14, 2026
This panel of women tax counsel and executives at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, analysed the challenges and opportunities faced by in-house tax advisers in an environment characterised by constant regulatory changes, the emergence of AI and the complexity of international reforms such as Pillar Two.
Released on Dec 18, 2025
This session at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, explored whether the OECD’s global minimum tax project – Pillar Two – can survive a markedly changed political landscape. Co-chairs Ana Cláudia Akie Utumi and Greg Featherman gathered panellists from Europe, the United States and six Latin American jurisdictions to test the regime’s efficacy, likely trajectory and practical impact on tax incentives across the region.
Released on Dec 18, 2025
This panel at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, provided a comparative analysis of legislative changes, practical challenges and emerging trends in Argentina, Brazil, Colombia, Mexico, Switzerland and the United States. Key subjects included indirect transfer rules, treaty protections, anti-abuse measures, tax incentives, and the impact of international tax reforms such as Pillar Two.
Released on Dec 18, 2025
This panel at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, examined subjects such as the tax treatment applicable to a player’s image rights, FIFA’s tax regime when having a World Cup in any given country, and other tax matters related to specific court cases involving players were discussed. The panel also analysed the preferred option for the organisation of sports entities, as well as how the proposed changes included in the reform being discussed in the US could impact the taxation of sports.
Released on Dec 18, 2025
A dynamic panel of international tax professionals from across the Americas shared practical, boots-on-the-ground insight into tax planning for startups operating across borders. The discussion took place at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025.
Released on Dec 18, 2025
This panel at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, explored the evolution of wealth structuring in Latin America, addressing how global transparency and regulation have reshaped the role of trustees, advisers and legal practitioners. The session was divided into two main themes: an overview of emerging trends and challenges, and a detailed discussion on modern structuring strategies, jurisdictions and trust alternatives.
Released on Dec 18, 2025
This panel at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, gathered practitioners from across jurisdictions to discuss the evolving landscape of family offices. The discussion provided a comparative analysis of how family offices operate in various countries, the tax and legal frameworks they navigate, and the strategic role they play in wealth preservation.
Released on Dec 18, 2025
From the basement to the C-Suite, the ongoing volatility of global trade wars has opened up significant opportunities for trade professionals to provide strategic guidance amid regulatory uncertainty. This panel at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, offered a comprehensive overview of the trade measures currently in place across several key jurisdictions, including Brazil, Mexico, Argentina, the United States and Colombia.
Released on Dec 18, 2025
This panel at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, explored the legal structures governing trusts in each speaker’s country, practical issues arising in their use and emerging trends and challenges. The discussion aimed to provide a comparative overview of how trusts operate globally, focusing on both similarities and jurisdiction-specific complexities in their legal and practical applications.
Released on Dec 18, 2025
This panel at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, explored the complexities and distinctions of foreign tax credit regimes across various Latin American jurisdictions and their interaction with United States tax rules.
Released on Dec 18, 2025
This panel discussion at the 17th Annual US and Latin America Tax Practice Trends Conference in June 2025 looked at the tax aspects of reorganisations and migration opportunities in the US and Latin America. The panellists addressed key tax considerations and practical aspects of restructurings and migrations within their respective jurisdictions.
Released on Dec 18, 2025
This session at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2025, examined how Latin American jurisdictions are redesigning their tax and regulatory architecture to capture value from digital payment flows, particularly in cross-border contexts.
Released on Dec 18, 2025
The implementation of general anti-avoidance rules (GAARs) has been an attempt to prevent the use of tax treaties to enable tax evasion, granting a country’s tax authority enough power to disregard a particular corporate structure or transaction, and deny a benefit granted by a double taxation treaty when tax avoidance could exist. Even so, the task of GAARs comes with challenges, as the interpretation of ‘when’ and ‘how’ GAARs should be applied can vary from one country to another. This session at the 2024 IBA Annual Conference in Mexico City discussed the status on the implementation of GAARs in Brazil, Mexico, Switzerland and the Netherlands.
Released on Nov 25, 2025
This panel at the 2024 IBA Annual Conference in Mexico City addressed the main recent developments in the tax structuring of foreign investments into Mexico. Considering that such foreign investments are predominantly made by United States investors (41.4 per cent of investment over the period 2006–2024), and by Spanish investors (10 per cent of investment over the same period), the panel focused first on the main general tax implications arising in Mexico for foreign investors.
Released on Nov 25, 2025
Mandatory reporting obligations adopted by different jurisdictions have created tensions between fundamental principles such as solicitor-client privilege, confidentiality and transparency. As countries implement stricter reporting regimes, different parties face challenges balancing compliance with these principles. This panel at the 2024 IBA Annual Conference in Mexico City discussed the approaches and current developments in different countries on these subjects.
Released on Nov 25, 2025
This panel at the 2024 IBA Annual Conference in Mexico City provided an in-depth exploration of the challenges and opportunities that AI presents to taxation and transfer pricing. Experts from various countries, including Argentina, Brazil, Mexico, South Korea and Spain, addressed how AI impacts value chains, the evolving role of AI in tax administration, and the regulatory frameworks needed to ensure fair practices.
Released on Nov 25, 2025
This panel discussion at the 2024 IBA Annual Conference in Mexico City examined the complexities associated with the employer of record (EOR) model in global employment contexts. The panel featured legal experts from different regions, who shared their insights on the challenges, limitations and operational strategies associated with EORs.
Released on Nov 25, 2025
This panel at the 2024 IBA Annual Conference in Mexico City addressed the primary fiscal challenges associated with cross-border corporate and executive mobility, including issues related to permanent establishments, place of effective management and their consequences – such as exit taxes – in Brazil, Italy, Mexico, Portugal, Switzerland, and the United States.
Released on Nov 25, 2025
This panel at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024, analysed how different countries implement new tax regimes in the digital economy era, particularly by addressing the current legislative landscape and the challenges experienced and efforts made by each jurisdiction.
Released on Nov 24, 2025
This panel at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024 addressed on a country-by country basis the various tax considerations for startup businesses in Latin America looking to expand both domestically and abroad. Additionally, the panel also discussed the tax considerations for US businesses looking to expand into Latin America.
Released on Nov 24, 2025
Domestic law is often used to combat abuse and tax planning. Some countries apply anti-avoidance rules independently if there is no anti-avoidance clause included in the relevant tax treaty to avoid double taxation. Other tax treaties expressly authorise it, among others due to the entry into force of the multilateral instrument. Clients are increasingly facing the application of general anti-avoidance rules (GAARs) in connection with anti-avoidance rules included in tax treaties, together with increased mandatory disclosure rules (MDRs). This panel at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024, discussed GAARs and MDRs in several jurisdictions, and the impact thereof on client advice.
Released on Nov 24, 2025
This panel – at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024 – focused on the evolving landscape of tax transparency and compliance for high net worth (HNW) individuals and multinational businesses in the US and Latin America.
Released on Nov 24, 2025