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Clinging to the changing face of APAs
Since APAs became an option for corporate taxpayers, there has been a gradual shift in their purpose and a split in taxpayer and government approaches to the agreements. Catherine Snowdon discovers how the process of getting an APA needs to develop to better suit modern business.
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Congress blows whistle on economic substance
When the US Congress codified the long-standing common law doctrine known as economic substance, many tax practitioners were not shy about criticising the move, expressing concern about the effects of this new law on corporate tax planning. Erin Kelechava spoke to tax lawyers, professors, and policy experts and found out that a statute that was meant to clarify what an abusive transaction is may end up achieving the opposite result.
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Teamwork relieves demands on tax directors
The most admired tax directors in Europe, from a poll of International Tax Review's readers, reveal what has changed about their roles since the beginning of widespread recession. Cooperation with their business colleagues has become closer and they still value the external advisers that get to know their business properly
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Plan your next move
Revenue authorities around the world have become an important tool for governments as they strive to raise income to boost their battered economies after the economic downturn of the last two years. And officials have put pressure on taxpayers to be transparent in their tax planning. The advisers who can ensure this level of service are to the fore in International Tax Review's third annual poll to find the world's leading planning practices
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Supreme Court re-enters anti-avoidance arena
For Canadian taxpayers and tax professionals, the general anti-avoidance rule, or GAAR, is synonymous with uncertainty. A new Supreme Court case will address some of the inconsistencies that have developed in the 18 years since the country enacted it. Erin Kelechava speaks to lawyers and the Canadian Revenue Agency about the court cases that have developed the doctrine and where they think the interpretation of GAAR is headed.
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Global tax transactional survey
Throughout the world, tax transactional advisers have adapted their advice to best support their clients during the economic downturn. Jack Grocott, Catherine Snowdon and David Stevenson speak to advisers and taxpayers in Asia, Europe and North and Latin America.
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India's Direct Tax Code unscrambled
A little more than six months ago, Indian officials asked taxpayers to comment on a new 256-page document that ripped up the country's 49-year-old income tax law. This was the first time that a tax law had been passed to taxpayers for consultation of any sort. The document, known as the Direct Tax Code (DTC), introduced widespread changes to the tax system all in the name of simplification and ease of use. But now, Jack Grocott discovers taxpayers and tax professionals are concerned that the code needs a drastic overhaul if India is to operate with an internationally-respected tax system that attracts foreign investment.
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