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Marnin Michaels

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Marnin Michaels is a partner in Baker & McKenzie´s Zurich office. He has been practicing for more than 15 years in the areas of tax and international private banking and handles insurance matters relating to tax investigations and wealth management. He counsels clients on US withholding tax and qualified intermediary rule, as well as money laundering avoidance legislation. Mr. Michaels was a member of the firms Steering Committee leading the US Department of Justice Initiative for Swiss Banks. In the end, the firm acted for 45 banks and the project won litigation firm of the year by American Lawyer Magazine.

In brief After much anticipation, the OECD released the ‘Blueprint’ for their Pillar Two proposal on 12 October as part of its two pillar package to deal with the increasing digitalisation of the economy. The premise behind the Pillar Two proposal is simple, if a state does not exercise their…

In brief The Baker McKenzie Global Tax Team has undertaken an in-depth analysis of the ‘Blueprint’ for the Pillar One proposal to produce a digestible summary of everything you need to know. To read our summary of the Blueprint for Pillar Two please click here. Contents CHAPTER 1 – INTRODUCTION TO…

Access the latest edition of the EMEA Transfer Pricing Guide on our TaxShare platform The 2020 EMEA Transfer Pricing Guide provides you with a detailed overview of the transfer pricing regime in many key jurisdictions across Europe, Africa, and the Middle East region. The guide outlines transfer pricing rules and…

Following a recent announcement of the European Commission’s proposal for a three-month deferral of reporting deadlines under the new DAC6 mandatory disclosure regime in the EU and UK, the Committee of the Permanent Representatives of the Governments of the Member States to the European Union (COREPER) has now reached an agreement on a revised proposal which could possibly defer the reporting deadline for six months. On the basis that the draft Directive, once approved, may be adopted at the discretion of each member state, it is imperative that businesses do not delay in preparing to meet their existing compliance obligations should reporting dates not be deferred (or not be deferred in all Member States where they operate).

In addition to the human tragedy, COVID-19 challenges the financial sector’s operating and business models and engages a wide range of law and regulation. As organizations strive to maintain business continuity and protect their workforce, they will face competing legal and regulatory pressures, particularly those operating on a cross-border basis,…

As the 2019 Novel Coronavirus (COVID-19) continues to spread across the world and restrictions to the mobility of people and goods increase, businesses are facing weakened financial markets, as well as disruption to workplace operations and business pipelines. Tax authorities across the globe have enacted amendments in order to cope…