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  • GAAR: empty threat or deal stopper?

    General anti-avoidance rules fill tax advisers the world over with trepidation. With good reason? Oliver Ralph compares practices and precedents across international jurisdictions, to discover the substance behind the rules


Features

  • GAAR: empty threat or deal stopper?

    General anti-avoidance rules fill tax advisers the world over with trepidation. With good reason? Oliver Ralph compares practices and precedents across international jurisdictions, to discover the substance behind the rules

  • IRS raises the reporting stakes

    New regulations on non-US partnerhips have been introduced in the US. Michael Cooper and Stan Torgersen of Deloitte & Touche LLP, Washington DC, advise readers on who should report and to what extent reporting is required

  • Securing success in Japan

    Asset securitization is increasingly accepted by Japanese corporations and institutions as a financing technique, and by investors as a suitable investment. Dean Yoost and Sachihiko Fujimoto, Pricewaterhouse-Coopers, Tokyo, provide practical guidance

  • US planning for ACT – part two

    The foreign tax credit treatment of UK ACT in the US continues to be a thorny issue for many taxpayers. Lawrence A Pollack, KPMG New York, David Porter and Frances Corrie, KPMG London examine the pieces of the puzzle and suggest solutions

  • The combined benefits of classification

    In an international context, making use of different classification rules for debt and equity can create hybrid financing instruments. Harry Doornbosch and Allert Kramer, PricewaterhouseCoopers, New York look at the hybrid options from a Dutch perspective

  • European supply chain strategies

    European Monetary Union (EMU) will affect the European group on two levels – structural and technical. Ernst & Young’s international tax group London examines some of the most striking of the structural business effects, and highlights technical pitfalls.

  • How to make the most of hybrids

    The IRS has reined in the almost unbridled opportunities presented by check-the-box, but international opportunities still exist. By Shawn Carson (BDO Seidman, New York), Allan Cinnamon and Zigurds Kronbergs (BDO Stoy Hayward, London)

  • Pass the German purpose test

    Germany has inaugurated a new era of opportunities for shareholder buybacks. Wolfgang Oho and attorney at law Günther Bredow, of Pünder, Volhard, Axster & Weber in Frankfurt, examine the balance sheet and fiscal considerations


News Analysis


International Correspondents


International Correspondents