Tax Law

Recent Posts

High Court Ruling Denies Legal Advice Privilege To Accountants’ Tax Advice
Posted on 30 Oct 2009 by Peter Nias, Andy Moody, David Jacob

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... Read More

At Cross Purposes: Recent International Tax Developments in India
Posted on 9 Feb 2010 by Kumar Paul and John Engel

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... Read More

Recent ECJ Decision Declares Unlawful the UK 1.5 Per Cent Stamp Duty Reserve Tax on Issues of Shares into Clearance Service
Posted on 9 Oct 2009 by Peter Nias, David Jacob, James Ross

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... Read More

India Makes Another Attempt at the India-Mauritius Tax Treaty
Posted on 20 Nov 2009 by Leonard Schneidman

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... Read More

Congress Enacts International Tax Legislation, Limits Use of Foreign Credits
Posted on 9 Sep 2010 by McDermott Will & Emery

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;... Read More

UK Government Proposals for Reform of the CFC Rules
Posted on 9 Feb 2010 by Peter M.W. Nias and James Ross

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... Read More

New International Tax Provisions Take Aim at Foreign Tax Credit Planning But Also Provide Some Relief Under Section 6501(c)(8)
Posted on 23 Aug 2010 by Eversheds Sutherland LLP

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... Read More

China Tax Planning for Japanese MNEs
Posted on 18 Oct 2012 by McDermott Will & Emery

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... Read More

Duane Morris LLP: New 2012 Offshore Voluntary Disclosure Program; Taxpayer Advocate Criticizes IRS "Bait & Switch"; Current Offshore Enforcement Initiatives
Posted on 25 Jan 2012 by Duane Morris LLP

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... Read More