High Court ruling on legal advice privilege means that advice given on tax law from accountants and other non-lawyers is vulnerable to disclosure; taxpayers should consider including lawyers from an early stage in any projects.
In a judgment dated...
During the latter part of 2009, the tax authorities of India continued to aggressively pursue the taxation of international transactions with direct and indirect connections to India. At the same time, a series of conflicting Indian court decisions and...
Recent decision by the European Court of Justice declares that a stamp duty reserve tax levied by HM Revenue & Customs contravenes European Council Directive 69/335/EEC and is unlawful.
On 1 October 2009, the European Court of Justice (ECJ) held...
In yet another attack on the India-Mauritius Tax Treaty (a time-honored route for inbound investment into India), several provisions in the new draft Indian Direct Tax Code (Draft Code), announced on August 12, 2009 and scheduled to come into force on...
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;...
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...
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...
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...
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)