Tax Law

Recent Posts

UK's Foreign Profits Reforms Cause Multinationals to Move to Other Countries
Posted on 1 Feb 2010 by Jyoti Dialani

Recent changes to the UK's economic reforms and taxation of foreign profits have caused the holding companies of major US corporations (e.g., MacDonald's) to relocate their headquarters from the UK to other European countries (e.g., Switzerland... Read More

Practical Strategies for Investment in the U.S., Europe and Asia Building Blocks Four Key Strategies in International Tax Structuring
Posted on 28 Sep 2009 by USC Gould School of Law

Summary : Though practical limitations wiill prevent most practitioners from dispensing advice regarding foreign tax laws, a U.S. tax practitioner may, nevertheless, effectively structure investments in a tax efficient manner without completely deferring... Read More

President Obama's International Tax Proposals in a Policy Context
Posted on 2 Jul 2009 by William H. Byrnes IV

Faced with growing pressure to close the rapidly increasing budget deficit, President Obama outlined a series of proposed changes to the international tax system. The plan is touted as 'levelling the playing field' and filling tax loopholes that... Read More

Economic Substance, Tax Benefits, and Schering-Plough v. U.S.
Posted on 2 Nov 2009 by Robert Jennings and Elizabeth Sweigart

In Schering-Plough Corporation v. United States , 2009 U.S. Dist. LEXIS 77467 , the courts decision for the Government is a clarion call to taxpayers that even in cases when the taxpayer may be technically in compliance with relevant law, transactions... Read More

Taxability of Foreign Companies' Fees for Bio-Analytical Services in India
Posted on 6 Feb 2009 by Jyoti Dialani

Jyoti Dialani discusses a recent ruling by the Authority for Advance Rulings (AAR) in India. The AAR provides tax relief to overseas companies engaged in providing research facilities for clinical and bio-analytical studies to Indian companies for developing... Read More

Arbitration Use in International Tax Treaties
Posted on 30 Sep 2008 by Robert Feinschreiber, Margaret Kent, and Paul E. M

While arbitration has traditionally been considered primarily an instrument to resolve private sector commercial disputes, it has been gaining ground with certain public sector institutions as well. In recent years, there has been explosive growth in... Read More

The Tax Axe on Cross-Border Deals in India: A Perspective
Posted on 21 Oct 2008 by Jyoti Dialani

Recently the Income-tax Department in India has focused on foreign companies involved in acquiring companies by purchasing controlling stakes in Indian companies by foreign companies usually routed through tax havens such as Mauritius, Cyprus and the... Read More

IRS Summonses Issued to Third Parties per Treaty Partner's Request
Posted on 18 Nov 2008 by Rufus Rhoades

Rufus v. Rhoades, Esq., co-author of the treatise Rhoades & Langer, U.S. International Taxation and Tax Treaties , discusses the law supporting a request for documents from a third party (usually a bank) in response to a request by a treaty country... Read More

Recent Developments in Treasury's FBAR Program
Posted on 8 Feb 2010 by Rufus v. Rhoades and Yariv Brauner

Recent Activity . The IRS recently issued a new version of the FBAR form (October 2008), and added new guidance in the form of frequently asked questions documents (September, June, and May 2009). That guidance is important as there are no traditional... Read More

Taxation of Canadian Mining Operations - Provincial Taxes
Posted on 6 Jun 2011 by LexisNexis Tax Center

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... Read More

Cross-Border Investment Strategies
Posted on 28 Sep 2009 by USC Gould School of Law

When structuring investments across international borders, one must know not only U.S. law, but also the tax rules of the foreign jurisdiction In addition, the practitioner must also have an in depth familiarity with the clients organizational structure... Read More

Turkey / Italy and Turkey / Spain Prevention of Double Taxation Treaties and Their Impact on Cross-Border Transactions
Posted on 15 Feb 2010 by Ali I Sanver

[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... Read More

Amended France - U.S. Treaty in Effect
Posted on 1 Nov 2010 by Withers Bergman LLP Tax Practice

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... Read More

Economic Turbulence Spurs Transfer Pricing Analysis
Posted on 9 Oct 2009 by Robert Feinschreiber and Margaret Kent

SUMMARY : The interface between the downward economic turbulence and governments transfer pricing objectives became an important facet of the OECDs Global Forum on Tax Treaties and Transfer Pricing,held September 21-22, 2009 in Paris. Among attendees... Read More

Government of the Grand-Duchy Decision to Adopt OECD Standard on Terms of Exchange of Information in Tax Matters
Posted on 26 Nov 2009 by Yann Baden

Luxembourg has long been a major banking center, but in recent years that status has been threatened by charges that its banks condone money-laundering and tax evasion. The Grand-Duchy has now moved to assuage its partners in this respect while maintaining... Read More