UK Government Proposals for Reform of the CFC Rules

Interested parties have until 20 April 2010 to comment on the UK Government’s proposals to reform the Controlled Foreign Companies rules. After the introduction in 2009 of a corporation tax exemption for foreign dividends, 26 January 2010 saw the start of the next stage of the United Kingdom’s...

Turkey / Italy and Turkey / Spain Prevention of Double Taxation Treaties and Their Impact on Cross-Border Transactions

[The] author believes that the deemed (notional) foreign tax credit available under the Spain/Turkey and Italy/ Turkey tax treaties might offer (additional) benefits in relation to cross-border lending and investments in debt and equity issues, provided that local tax offices can be convinced to apply...

The Impact of Veritas Software Corp. v. Comm'r on Intellectual Property Transfer Pricing by U.S. Multinationals

In light of... Veritas Software Corp. v. Comm'r, 2009 U.S. Tax Ct. LEXIS 34 (T.C. Dec. 10, 2009) , U.S. multinationals should give careful consideration to the manner in which their IP is created, held and paid for. ... In January 1999, the company established Veritas Software Holding, Ltd...

Sorry Margaret, No Tea Parties in London

Why is there no equivalent to the Tea Party movement in the United Kingdom?... A cursory review of the tax issues featuring in the May 6 election suggests that, if anything, the Tories are moving decidedly to the center. That's just the opposite of what's happening on this side of the Atlantic...

LexisNexis® Tax Practice China Service Improvements Announced

Refinements to LexisNexis® Tax Practice introduced by LexisNexis China are discussed in recent releases by Business Wire and by XooArticles.com .

Transfer Pricing Abuse Is Job-Killing, Corporate Welfare

I had the privilege of testifying before the Ways and Means Committee [on July 22nd]. Below is the text of my oral testimony. The official witness testimony can be found here . And the excellent pamphlet by Joint Committee on Taxation is here . Mr. Chairman, there is overwhelming evidence of inordinate...

New International Tax Provisions Take Aim at Foreign Tax Credit Planning But Also Provide Some Relief Under Section 6501(c)(8)

By Carol Tello and Giovanna Sparagna On August 10, 2010, President Obama signed into law the Education Jobs and Medicaid Assistance Act, P.L. 111-226, which provides funds to the states for teachers' salaries and Medicaid costs. To fund this bill, Congress enacted all but one of the international...

Congress Enacts International Tax Legislation, Limits Use of Foreign Credits

By David G. Noren , James A. Riedy, PC , Lowell D. Yoder , Robert A. Clary, II and Menna Eltaki Congress recently enacted international tax provisions that were previously designated as revenue raisers in the not-yet enacted Extenders Legislation; prospective effective dates allow time for necessary...

Amended France - U.S. Treaty in Effect

By Mitchell R. Kops , Sanford J. Davis , and William J. Kambas A new France-U.S. income tax treaty protocol... O nce ratified by both countries, and after exchange of instruments and entry into force, the Protocol will become effective in three stages: (i) First, the new withholding tax provisions...

Taxation of Canadian Mining Operations - Provincial Taxes

By Peter C. Maxfield, Robert M. Allen CPA and J. Andrew Miller CPA Editor's Note: This Emerging Issues Analysis is an edited excerpt from Chapter 13 of the LexisNexis Matthew Bender title Taxation of Mining Operations . ... Each of the provinces and territories of Canada imposes its own...

Duane Morris LLP: New 2012 Offshore Voluntary Disclosure Program; Taxpayer Advocate Criticizes IRS "Bait & Switch"; Current Offshore Enforcement Initiatives

By Thomas W. Ostrander 2012 Offshore Voluntary Disclosure Program Announced by IRS: Details and Issues On January 9, 2012, the Internal Revenue Service (IRS) announced that it had reopened the Offshore Voluntary Disclosure Program (OVDP) following the closure of the 2011 and 2009 programs and the...

Foreign Tax Credit, Partnerships and Disregarded Entities: The Latest Rules

[Editor's Note: This narrative is derived from Rhoades & Langer, U.S. International Taxation and Tax Treaties, § 12.02[3][a][ii][B] (Matthew Bender).] The foreign tax credit is the international taxpayer's chief defense against double taxation of the same items of income, once by...

China Tax Planning for Japanese MNEs

By Cym H. Lowell , Partner Japanese multinational entities with current or future operations in China must plan to address a series of issues. Many of the critical international taxation and transfer pricing issues framed by activities in China are only just emerging or remain in an ambiguous context...

China Tax Planning for Japanese MNEs

By Cym H. Lowell , Partner Japanese multinational entities with current or future operations in China must plan to address a series of issues. Many of the critical international taxation and transfer pricing issues framed by activities in China are only just emerging or remain in an ambiguous context...

Regulators Target 2013 Start for Basel III Rules on Capital, Liquidity

[ Editor's Note : This narrative is derived from Taxation of Financial Institutions § 1.12 (Matthew Bender) .] ... Basel III is a global regulatory standard on the adequacy of bank capital and market liquidity requirements agreed upon by members of the Basel Committee on Banking Supervision...

Regulators Target 2013 Start for Basel III Rules on Capital, Liquidity

[ Editor's Note : This narrative is derived from Taxation of Financial Institutions § 1.12 (Matthew Bender) .] ... Basel III is a global regulatory standard on the adequacy of bank capital and market liquidity requirements agreed upon by members of the Basel Committee on Banking Supervision...