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How companies create tax regimes in emerging countries
Multinational companies, especially in the energy and extractive industries, are playing a significant role in structuring the tax systems in emerging countries. Joanna Faith discovered how businesses balance their commercial objectives with a wider role in helping with governments

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     Cover Story
    blank How companies create tax regimes in emerging countries
    Multinational companies, especially in the energy and extractive industries, are playing a significant role in structuring the tax systems in emerging countries. Joanna Faith discovered how businesses balance their commercial objectives with a wider role in helping with governments May 2008

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    blank FIN 48: Quantifying the unknowable
    As FIN 48 enters its second year, Bob Reynolds discovers that it remains a thorn in the side of many corporate tax departments April 2008

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     Features
    blank New prosecutor steps in to take on evasion
    Nathan Hochman has just become the government's chief prosecutor of the US tax code. He tells Catherine Snowdon about his strategy for convicting taxpayers who don't abide by the rules May 2008

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    blank Fay arrives to strengthen AIG's tax force
    AIG turned to private practice when it needed someone to run its tax department in Asia. Tony Fay came to the role in awe of the size of the company and the issues he and his team have to deal with throughout the region. Ralph Cunningham spoke to him in Hong Kong about how he intends to embed tax as a key part of the company.  May 2008

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    blank Managing a company's effective tax rate
    Adrian Windsor and Jeremy Curd, of PricewaterhouseCoopers in the UK, discuss the value of managing a company's effective tax rate May 2008

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    blank Voluntary disclosure becomes a necessity
    Scott Michel of tax boutique Caplin & Drysdale argues that companies and tax professionals should seriously consider the Internal Revenue Service's voluntary disclosure programme May 2008

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    blank Tackling global concerns
    Werner Stuffer argues that Germany's recent tax reform is a missed opportunity. Joanna Faith spoke to him about the challenges he faces in dealing with revenue authorities as Siemens' vice president of international tax May 2008

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    blank US Senate Finance chief plots course to tax reform
    Americas correspondent Catherine Snowdon examines the plans for tax reform in the US Senate May 2008

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    blank Firms reach the heights in tax planning
    The biggest professional services firms are near or at the top of International Tax Review's first poll of the world's leading planning practices. And law firms and smaller consultancies are also competing to offer bespoke tax structuring, transfer pricing and indirect tax advice May 2008

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    blank US hi-tech taxation needs addressing
    Hillary Clinton recently announced an agenda that would bring significant tax incentives for the hi-tech industry to in-source work and create new jobs in the US, Catherine Snowdon finds out why the tax treatment of US hi-tech companies has become such an area of focus May 2008

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    blank China issues plethora of new tax rules
    Jeffery Kadet and Kevin Zhu of Deloitte in Shanghai report on the raft of new rules in China published since the Enterprise Income Tax became law April 2008

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    blank Thin-capitalisation reforms favour high-income earners
    Giuseppe Galeano and Alan Rhode of Camozzi Bonissoni Varrenti argue that Italy's replacement regime for thin capitalisation favours high business income earners April 2008

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    blank Darling's budget leaves multinationals waiting on foreign profits
    Ralph Cunningham and Joanna Faith report on the UK Budget, gauging comment from industry and advisers April 2008

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    blank Indian Budget aims to boost spending growth
    Vispi Patel and Rajesh Athavale, of PricewaterhouseCoopers in India, argue that finance minister Palaniappan Chidambaram's Budget seeks to achieve fiscal consolidation April 2008

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    blank Planning for high turnover
    Catherine Snowdon met Sempra Energy's San Diego based tax team and discovered its priorities April 2008

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    blank New rules tighten scope for carrying forward tax losses in share transfers
    Ingrid Turner and Christof Zondler of Deloitte in Stuttgart argue that despite simplifying the rules, the new Business Tax Reform Act limits the application of tax loss carryforwards in corporate share transfers April 2008

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    blank A healthy dialogue with taxpayers
    Frank Ng seeks consistency and uniformity in dealing with non-compliance. He talks to Americas correspondent Catherine Snowdon about his approach to running the Large and Midsize business group at the Internal Revenue Service April 2008

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    blank Sponsored feature: Outsourcing: fool's gold?
    Ian Sadler and Peter Clements of Ernst & Young asks whether compliance outsourcing has been a victory of style over substance and examines what organisations should be looking for from their outsourcing contract and from their service provider April 2008

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    blank The tax talent pool diminishes
    Joanna Faith uncovers some alarming trends for businesses seeking to recruit able tax people April 2008

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    blank Sovereign wealth funds become visible
    Sovereign wealth funds have recently become a talking point worldwide. Yet Babak Nikravesh, of law firm Heller Ehrman, says that they have been a consistent feature of US investment for decades April 2008

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    blank Ending the flaws in double tax treaties
    The purpose and function of double tax treaties is one of the hottest issues in international tax. The OECD at its meeting with tax advisers in Tokyo in March identified this as a critical issue. Monique van Herksen and Haig Oghigian of Baker & McKenzie in Amsterdam examine the principal issues. April 2008

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     Comment
    blank New UK Chancellor starts by listening in first budget
    Following on from their Budget web seminar, Chris Sanger and Patrick Stevens of Ernst & Young discuss the measures announced in the 2008 UK Budget and their likely impact May 2008

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    blank Editorial
     May 2008

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    blank Canada reduces tax reporting for non-residents
    Todd Miller and Michael Friedman of McMillan Binch Mendelsohn explain how non-residents will benefit from new measures announced in the 2008 federal budget April 2008

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    blank Portugal makes stand against abusive tax planning
    Rogério Fernandes Ferreira, António Fernandes de Oliveira and Andreia Pereira da Costa, of law firm PLMJ in Lisbon, argue that the government has chosen wide-ranging definition of abuse April 2008

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    blank Editorial
     April 2008

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     News
    blank Draft regulations point to tougher transfer pricing audit regime in China
     May 2008

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    blank Australia-South Africa protocol reforms withholding tax rates
     May 2008

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    blank French consult on documentation rules
     May 2008

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    blank Roche scores significant victory over Australian Taxation Office
     May 2008

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    blank APA report shows drop in figures
     May 2008

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    blank Spanish court rejects intra-group services appeal
     May 2008

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    blank Marks & Spencer comes out on top in teacake VAT judgement
     May 2008

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    blank High taxes drive pharmaceutical company out of UK
     May 2008

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    blank CCCTB proposal date is in doubt
     May 2008

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    blank Cargill India wins transfer pricing documentation row
     May 2008

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    blank Merz sets up working group on Swiss tax competition
     April 2008

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    blank Talks to revise double tax treaty between India and Mauritius fail
     April 2008

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    blank Canada's provinces focus on tax changes
     April 2008

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    blank Treasury and Congress struggle with derivatives taxation
     April 2008

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    blank EC consults on reduced VAT rates
     April 2008

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    blank NZ ministers act on stapled securities
     April 2008

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    blank Mumbai court postpones Vodafone capital gains judgement
     April 2008

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    blank European Commission challenges Spain on anti-abuse rules
     April 2008

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    blank Thai government seeks to cut corporation tax rate by five percentage points
     April 2008

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    blank East African Community aims for elimination of double tax
     April 2008

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    blank US produces new guidance on contract manufacturing and subpart F
     April 2008

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     People and Firms
    blank ABI boosts tax team
     May 2008

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    blank KPMG moves senior tax specialist to the Gulf
     May 2008

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    blank McGowan leaves Shearman & Sterling
     May 2008

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    blank Green fronts new London international tax team
     May 2008

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    blank Ernst & Young bags two transfer pricing specialists from Deloitte
     May 2008

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    blank Derouin moves on from Linklaters
     April 2008

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    blank Key transfer pricing appointments made worldwide
     April 2008

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    blank Jefferson Wells announces two high level tax recruits
     April 2008

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    blank Ong Sim Ho moves to bigger firm
     April 2008

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    blank Choong to leave Drew & Napier
     April 2008

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    blank Bassett leaves Fenwick & West
     April 2008

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    blank Castillo joins Transfer Pricing Associates in Madrid
     April 2008

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    blank Davison named tax partner at Freshfields
     April 2008

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    blank Washington DC law firm recruits Breen from the IRS
     April 2008

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     Tax relief
    blank Tax relief
    A monthly commentary on the notable facts, figures and goings-on in the tax world, so called to give you a gentle exit from International Tax Review each month May 2008

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    blank Tax relief
    A monthly commentary on the notable facts, figures and goings-on in the tax world, so called to give you a gentle exit from International Tax Review each month.  April 2008

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     Deals
    blank Who's worked on the biggest deals
     May 2008

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    blank Who's worked on the biggest deals
     April 2008

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    blank US real estate tax critical in Irish utility deal
    Joanna Faith reports on Scottish and Southern Energy's acquisition of Airtricity April 2008

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    Mergers & Acquisitions Latin America Intellectual Property Indirect Taxes
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    India Switzerland Ireland North America
    click4more

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    European Commission takes action over breaches of tax rules
    May 8, 2008

    Action Aid report slams companies for avoiding tax
    May 7, 2008

    Canadian tax court issues Prevost ruling on beneficial ownership
    May 7, 2008

    Australian tax investigation forces Vanuatu to abandon banking secrecy
    May 6, 2008

    UK opposition parties clash over corporate tax cuts
    May 6, 2008

    Shortlists for European Tax Awards revealed
    April 30, 2008

    UK chancellor unveils new tax policy group
    April 29, 2008

    United Business Media plans to move tax residence out of UK
    April 29, 2008

    more...

    supplement header
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    Taxation of companies' foreign profits
    Ruling on the taxability of a foreign company carrying out money transmission services
    FIN 48 and tax audits
    New regime provides new way to calculate taxes
    Congress reviews international tax legislation
    Is there anything beyond transfer pricing?
    Supreme Court rules on international treaties
    Tax treaty with France amended
    IRS issues final regulations under section 1248
    The LIMOSA-registration or the monitoring of temporarily employment in Belgium
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