Insights
INSIGHTS
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Electronic Judicial Domicile
Mar 2026Read moreEstablished by the National Council of Justice (Conselho Nacional de Justica – CNJ), the Electronic Judicial Domicile (Domicilio Judicial Eletronico) centralizes, in a single environment, judicial service of process and procedural notifications, whose availability marks the beginning of the legal knowledge and the commencement of procedural deadlines, with a direct impact on the visibility and management of such deadlines. Co...
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Obligations of Limited Liability Companies with the IRS - Filing of Form 5472
Mar 2026Read moreU.S. limited liability companies ("LLCs") wholly owned by a single individual or legal entity that is not a resident of the United States of America ("U.S.") are classified, for these purposes, as foreign-owned U.S. disregarded entities and may be subject to the annual filing of Form 5472 with the Internal Revenue Service ("IRS"). This form is intended to report transactions carried out, in the prior fiscal year, between such...
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Deadline for Filing the Reference Form and the Electronic Compliance Declaration with the CVM Falls on March 31, 2026
Mar 2026Read moreThe deadline for securities portfolio managers and securities consultants — whether individuals or legal entities — holding an active registration with the Brazilian Securities and Exchange Commission ("CVM") to complete the annual update of the Reference Form ("FR") and to submit the Electronic Compliance Declaration ("DEC"), based on the positions as of December 31, 2025, falls on March 31, 2026, pursuant to CVM Resolutions...
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CVM Expands the Possibility of Assignment to FIDCs of Receivables by Companies Under Restructuring Proceedings
Mar 2026Read moreThe Brazilian Securities and Exchange Commission ("CVM") published, on March 6, 2026, Resolution No. 240 ("RCVM 240"), which amended Normative Annex II of Resolution No. 175, dated December 23, 2022 ("RCVM 175"), governing the specific rules applicable to receivables investment funds (fundos de investimento em direitos creditórios, "FIDC"). The rule concerns the regulatory treatment applicable to receivables assigned by compa...
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Amendments to the General Rules on ITCMD and ITBI in the Tax Reform
Jan 2026Read moreOn January 14, 2026, Complementary Law No. 227/2026 ("LC No. 227/2026") was published, introducing relevant amendments to the national tax legislation, particularly in the context of the Tax Reform. Set forth below are the most relevant aspects of the new legislation with respect to the following taxes: ITCMD: Tax on Transfer Causa Mortis and Donations, levied by the States and the Federal District ITBI: Tax on Onerous...
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LC No. 224/2025: Reduction of Tax Benefits, Increase in Deemed Profit Regime Margins
Jan 2026Read moreOn December 26, 2025, Complementary Law No. 224/2025 ("LC No. 224/2025") was published, introducing several relevant amendments to the tax legislation, in particular (i) the reduction of various tax benefits, (ii) the increase in deemed profit margins for the Assumed Profit (Lucro Presumido) regime; (iii) the increase in the Social Contribution on Net Income (CSLL) rate applicable to certain financial institutions; and (iv) th...
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Central Bank of Brazil Regulates Banking as a Service (BaaS)
Dec 2025Read moreThe Central Bank of Brazil ("Bacen") and the National Monetary Council ("CMN") published, on November 28, 2025, Joint Resolution No. 16 ("Joint Resolution No. 16"), establishing the regulatory framework for the provision of services under Banking as a Service ("BaaS") arrangements by financial institutions, payment institutions, and other institutions authorized to operate by Bacen. The new rule is the result of Public Consult...
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CVM Issues Guidance on FIDCs, FIAGROs, and FIIs
Nov 2025Read moreThe Securitization and Agribusiness Superintendency ("SSE") of the Brazilian Securities and Exchange Commission ("CVM") published, on November 17, 2025, Circular Letter No. 8/2025/CVM/SSE ("Circular Letter"), setting forth relevant clarifications on the application of provisions of Normative Annexes II, III, and VI to CVM Resolution No. 175, particularly with respect to the operation of Receivables Investment Funds (Fundos de...
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Congress Approves Bill No. 1,087 - Income Tax on Dividends and Minimum Income Taxation
Nov 2025Read moreThe Brazilian Congress approved Bill No. 1,087/2025, which establishes the taxation of profits and dividends distributed by Brazilian companies in certain circumstances, and introduces a minimum income tax for individuals, levied on income exceeding a specified threshold. The main changes introduced are set forth in the advisory available at this link.
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CVM Issues Public Consultation to Enhance the Rules Applicable to Real Estate Investment Funds (FIIs)
Nov 2025Read moreThe Brazilian Securities and Exchange Commission ("CVM") published, on October 30, 2025, Public Consultation Notice No. 06/25 ("Notice"), submitting to market participants a proposal to amend Normative Annex III of CVM Resolution No. 175, of 2022 ("RCVM 175"), which sets forth the specific rules applicable to real estate investment funds (fundos de investimento imobiliário – "FII"). The proposal seeks to modernize the regulat...
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Central Bank of Brazil Publishes New Security Measures for the National Financial System
Sep 2025Read moreOn September 5, 2025, the Central Bank of Brazil ("BCB") published a set of rules to strengthen the security of the Brazilian National Financial System (Sistema Financeiro Nacional – "SFN") and the payments ecosystem, in response to recent attacks attributed to organized crime. The measures seek to raise governance standards and restrict transactions by payment institutions ("PI") not subject to BCB supervision, as well as to...
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Declaration of Bank Accounts and Financial Investments Held Abroad: FBAR (Foreign Bank and Financial Accounts Report)
Aug 2025Read morePursuant to the Bank Secrecy Act of the United States of America ("U.S.") and the regulations issued by the Financial Crimes Enforcement Network ("FinCEN"), a division of the U.S. Department of the Treasury responsible for combating money laundering, individuals and legal entities resident or domiciled in the U.S. ("U.S. Persons") that hold, directly or indirectly, a financial interest (financial interest) or signature authori...