Tax Law

Recent Posts

Transfer Pricing Abuse Is Job-Killing, Corporate Welfare
Posted on 26 Jul 2010 by Martin A. Sullivan

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... Read More

PwC Served with Notice by Indian Apex Court
Posted on 12 Sep 2008 by Jyoti Dialani

PricewaterhouseCoopers (PwC) has been served with a notice by the Supreme Court of India in August to reply as to why it should not pay advance tax on fees charged by it for rendering professional services in India. PwC, a non-resident Indian partnership... Read More

Report: Swiss Banks Eye Tax Pledge for Foreigners
Posted on 16 Nov 2009 by Peter Miller

ZURICH – (AP) Swiss banks are considering asking some foreign clients to sign a pledge declaring they aren't breaking tax laws at home, a Swiss newspaper reported Sunday. The chairman of the Swiss Bankers Association, Patrick Odier, told... Read More

Sorry Margaret, No Tea Parties in London
Posted on 30 Apr 2010 by Robert Goulder

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... Read More

Yankee Fans Give Wall Street a Bronx Cheer
Posted on 11 Nov 2009 by Martin A. Sullivan

Savvy politicians are instinctively anti-intellectual. To win elections, emotion trumps reason every time. That's why in their crafting of financial reforms, Washington types are more likely to pay attention to Yankee fans chanting "Wall Street... Read More

Income From Bio-Analytical and Research Studies in India Exempt from Tax in Absence of PE
Posted on 3 Oct 2008 by Jyoti Dialani

In a ruling which will be welcomed by overseas companies engaged in research and bio-analytical studies in India , the Authority for Advance Rulings (AAR) hastaken a view that fees earned by such companies are not subject to tax if the companies do not... Read More

India Taxes Delta Airline's Baggage Screening, 3rd Party Charter Handling Income
Posted on 6 Apr 2009 by Jyoti Dialani

A recent ruling of the Mumbai Income Tax Tribunal in India in the case of Delta Airlines Inc., an American airline company has held that the company is not entitled to treaty benefits of exemption on certain incomes derived from related activities. Delta... Read More

The Exodus That Wasn't
Posted on 21 Sep 2009 by Robert Goulder

The results are in -- London's hedge funds are staying put despite Prime Minister Gordon Brown's controversial tax hike. That news directly conflicts with all we were told when the U.K. announced it was raising the top individual tax rate from... Read More

Should Tax Havens Pay for Bank Bailouts?
Posted on 30 Sep 2009 by Martin A. Sullivan

Now the big question that regulators and politicians avoid like the plague is this: after private-sector solutions have been exhausted, and it is agreed a bailout is necessary, how will governments allocate the cost of those bailouts? During the 2007... Read More

The Satyam - PwC Scandal: The Bleak Road Ahead
Posted on 14 Jan 2009 by Jyoti Dialani

Amidst the gloomy world economy and daily news of the global crisis, business closures and rising unemployment, the last thing one needed to hear was a financial fraud of mammoth proportions as the one exposed at Satyam Computer Services Limited, the... Read More

Twist in the Satyam - PwC Tale: Two Auditors Detained, Suspended
Posted on 2 Feb 2009 by Jyoti Dialani

India had not yet recovered from the shocking revelations of the biggest corporate financial fraud in the IT giant, Satyam Computer Service. A fresh development to hit the story is the detention of two auditors in the Indian arm of PwC, who were involved... Read More

Prospects for Corporate Tax Hikes in U.S. and Germany
Posted on 22 Sep 2009 by Martin A. Sullivan

After the September 27 election Angela Merkel is likely to retain her hold on leadership of the German government. The burning question is whether the Chancellor's conservative CDU party will continue the "grand coalition" with its main... Read More

The Sweet Illusion of Control
Posted on 9 Nov 2009 by Robert Goulder

Your taxes are about to increase. So are mine, and so are everybody elses. And there's nothing we can do about. It won't happen today or tomorrow, but it will happen soon -- and once the rates increase they will remain high for a very long time... Read More

  • Blog Post: PwC Served with Notice by Indian Apex Court

    PricewaterhouseCoopers (PwC) has been served with a notice by the Supreme Court of India in August to reply as to why it should not pay advance tax on fees charged by it for rendering professional services in India. PwC, a non-resident Indian partnership firm, has been issued this notice on an appeal...
  • Blog Post: Income From Bio-Analytical and Research Studies in India Exempt from Tax in Absence of PE

    In a ruling which will be welcomed by overseas companies engaged in research and bio-analytical studies in India , the Authority for Advance Rulings (AAR) hastaken a view that fees earned by such companies are not subject to tax if the companies do not have a permanent establishment (PE) in India. The...
  • Blog Post: The Satyam - PwC Scandal: The Bleak Road Ahead

    Amidst the gloomy world economy and daily news of the global crisis, business closures and rising unemployment, the last thing one needed to hear was a financial fraud of mammoth proportions as the one exposed at Satyam Computer Services Limited, the fourth largest software company in India, ranked after...
  • Blog Post: Twist in the Satyam - PwC Tale: Two Auditors Detained, Suspended

    India had not yet recovered from the shocking revelations of the biggest corporate financial fraud in the IT giant, Satyam Computer Service. A fresh development to hit the story is the detention of two auditors in the Indian arm of PwC, who were involved in the audit process of the ill-fated company...
  • Blog Post: India Taxes Delta Airline's Baggage Screening, 3rd Party Charter Handling Income

    A recent ruling of the Mumbai Income Tax Tribunal in India in the case of Delta Airlines Inc., an American airline company has held that the company is not entitled to treaty benefits of exemption on certain incomes derived from related activities. Delta, a company incorporated in, and a tax resident...
  • Blog Post: The Exodus That Wasn't

    The results are in -- London's hedge funds are staying put despite Prime Minister Gordon Brown's controversial tax hike. That news directly conflicts with all we were told when the U.K. announced it was raising the top individual tax rate from 40% to 50%. The higher rate applies to taxable income...
  • Blog Post: Prospects for Corporate Tax Hikes in U.S. and Germany

    After the September 27 election Angela Merkel is likely to retain her hold on leadership of the German government. The burning question is whether the Chancellor's conservative CDU party will continue the "grand coalition" with its main rival, the center-left SPD. ... The implications...
  • Blog Post: Should Tax Havens Pay for Bank Bailouts?

    Now the big question that regulators and politicians avoid like the plague is this: after private-sector solutions have been exhausted, and it is agreed a bailout is necessary, how will governments allocate the cost of those bailouts? During the 2007-09 crisis most of the cross-border bailouts have been...
  • Blog Post: The Sweet Illusion of Control

    Your taxes are about to increase. So are mine, and so are everybody elses. And there's nothing we can do about. It won't happen today or tomorrow, but it will happen soon -- and once the rates increase they will remain high for a very long time. That's the dire forecast contained in an IMF...
  • Blog Post: Yankee Fans Give Wall Street a Bronx Cheer

    Savvy politicians are instinctively anti-intellectual. To win elections, emotion trumps reason every time. That's why in their crafting of financial reforms, Washington types are more likely to pay attention to Yankee fans chanting "Wall Street sucks" than any in-depth report from financial...
  • Blog Post: Report: Swiss Banks Eye Tax Pledge for Foreigners

    ZURICH – (AP) Swiss banks are considering asking some foreign clients to sign a pledge declaring they aren't breaking tax laws at home, a Swiss newspaper reported Sunday. The chairman of the Swiss Bankers Association, Patrick Odier, told weekly NZZ am Sonntag that the industry group is...
  • Blog Post: 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...
  • Blog Post: 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...