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North America

  • Anti-inversion rule threatens foreign tax structuring plans

    The anti-inversion provisions enacted in 2004 tax legislation are overly broad and may result in significant adverse income tax consequences for many internal restructurings within an affiliated group of corporations, argues Kevin Rowe of Alston & Bird

  • Proposed cost-sharing rules put spotlight on buy-in payments

    John Hatch of The Ballentine Barbera Group considers two economic issues connected to the determination and subsequent audit of initial buy-in payments at the outset of a cost-sharing agreement

  • Tax authorities take on the treaty shoppers

    Jeffrey Trossman and Amanda Heale of Blake, Cassels & Graydon discuss how the Canada Revenue Agency is challenging transactions that seek to benefit from treaty shopping and analyze the approach of the courts on the issue

  • IRS tests new arm's-length and cost sharing theories in Tax Court

    James Fuller, Kenneth Clark, and William Colgin, Jr of Fenwick & West trace the emergence of the IRS' arguments in the Xilinx case, and the role of the new theories on cost sharing in the 2003 final regulations and the 2005 proposed regulations

  • Mexican Congress changes real estate and tax haven rules

    The annual tax reforms in Mexico will introduce important changes to the rules for real estate investment trusts, thin capitalization and tax havens, explain Carlos Montemayor, Carlos Orel Martinez and Francisco Jose Zamora of PricewaterhouseCoopers


International Correspondents