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  • Clients choose graft over glitter

    Ask a tax professional about the major tax advice developments of the last 12 months and the answers will highlight the firm’s success. Ask a client and a different story emerges. Rosie Murray-West asks corporate tax directors about their loves and hates


  • Clients choose graft over glitter

    Ask a tax professional about the major tax advice developments of the last 12 months and the answers will highlight the firm’s success. Ask a client and a different story emerges. Rosie Murray-West asks corporate tax directors about their loves and hates

  • Debate rages over German secrecy

    Alexander Vögele of KPMG in Frankfurt challenges the conclusions reached by Thomas Borstell and Michael Prick (ITR April 1999) regarding the court decision banning the use of secret comparables, a decision that has provoked considerable controversy in Germany

  • Harmonization moves closer by stages

    Many specialists believe that direct tax harmonization is years away. But, as Peter Nias and Nicola Purcell of McDermott, Will & Emery in London argue, recent EU initiatives and court decisions have quietly brought a unified tax system a step closer

  • Controversy fuels US anti-deferral plans

    Growing controversies such as the Notice 98-11 debate, have forced the IRS to reconsider its attitude towards CFCs. Andrew Immerman of Alston & Bird in Atlanta considers the debate and offers advice on how multinationals can plan amid the growing uncertainty

  • French CFCs face EU challenges

    France’s CFC rules were originally modelled on the US regime but revised tax treaties and EU directives have caused extra problems for French companies with CFCs. Patrick Dibout of Jeantet et Associés in Paris explains how government and taxpayers have reacted

  • Canada cracks down on CFCsv

    Canadian foreign affiliate rules have been compared to the US regime for their complexity. Ian Crosbie of Davies, Ward & Beck in Toronto explains the legislation and clarifies how new anti-abuse proposals could catch many taxpayers unawares

  • Belgium widens ruling options

    Belgium’s advance rulings procedure has existed since 1993. But recent legislation has expanded the range of rulings available. Marc de Munter of Freshfields Deringer in Brussels explains how multinationals can make the most of the new system

  • Mexico builds on promising start

    Mexico’s two year old transfer pricing regime has been running smoothly, but uncertainties remain, particularly over documentation rules and secret comparables. Miguel Valdés, William Hahn and Nicolás Muñiz of Ernst & Young, New York and Mexico City explain

  • Norway opens out credit regime

    The Norwegian foreign tax credit rules have been widened in recent years to allow Norwegian parent companies to claim more credits than were previously available. Unni Bjelland of Ernst & Young in Norway explains how to make the most of the new regime

News Analysis

  • Australia passes food-exempt GST

    The Australian government has passed a goods and services tax (GST) deal which may place an additional compliance burden on business.

  • E-commerce case raises avoidance spectre

    Tax officials are concerned that the expansion of e-commerce may lead to large-scale tax evasion in China, according to the official Wenhui Daily.

  • Accountants welcome MDP breakthrough

    Accounting firms have cautiously welcomed a report that could ease their transformation into multidisciplinary practices (MDPs). The report, by a commission of the American Bar Association (ABA), has recommended that lawyers should be allowed to practise law in organisations other than law firms. The ABAs' refusal to permit lawyers to practise in MDPs has been a stumbling block to the aspirations of the big five accounting firms.

  • UK legal privilege fight to continue after setback

    UK Companies and law firms have pledged to fight on after an amendment concerning the Inland Revenue's power to force companies to disclose legal correspondence fell in Parliament.

  • Businesses unimpressed by German tax cut

    Gerhard Schroder, the German Chancellor, has revealed a package of tax cuts worth at least Dm 8 billion ($4.2 billion) to business. But industry figures think the Chancellor has not gone far enough.

  • Hong Kong tax chief in conflict probe

    Wong Ho-Sang, head of Hong Kong's Inland Revenue Department, is being investigated for possible breaches of taxation law and civil service rules.

  • Michigan compromises on single business tax

    The State of Michigan has dropped its proposed taxation of foreign corporations, following intensive lobbying by Canadian trade associations.

  • Indian reform eases share buybacks

    The Indian government has passed the Companies (Amendment) Act, 1999 that makes some important amendments to the Companies Act, 1956, with effect from October 31 1998. Some of the most important changes are as follows.

  • British Steel turns to PwC

    PricewaterhouseCoopers is advising British Steel on its merger with Netherlands rival Koninkijke Hoogovens. The merged company will be the world's third-largest steel producer and will be called BSKH. It will seek listings in London, Amsterdam and New York. British Steel shareholders will hold a 61.7% stake in the company. BSKH will have a market capitalization of £2.65 billion ($4.3 billion).

  • Stagecoach consults Herbert Smith

    Herbert Smith is advising the UK's largest transport group, Stagecoach, on its purchase of Houston-based Coach USA. The purchase is valued at $1.8 billion, which includes the assumption of $571million of debt. This is Stagecoach's first US acquisition and gives the company a foothold in the North American transport sector. The deal is being financed through a $2.25 billion loan from Credit Suisse First Boston, JP Morgan and the Royal Bank of Scotland. Stagecoach will also later issue up to $1 billion in bonds and equity-related securities for refinancing.

  • Wachtell concocts chemical deal

    Wachtell Lipton Rosen & Katz, in New York, is advising Connecticut chemical maker Crompton & Knowles in its merger with chemical company Witco. The deal is valued at $1 billion, plus the assumption of $1 billion worth of debt.

  • Paul Weiss advises on real estate merger

    US law firm Paul Weiss Rifkind Wharton & Garrison is advising Trinet Corporate Realty Trust in its merger with Starwood Financial Trust in a $1.5 billion stock-for-stock transaction.

  • MCI turns to Cravath

    Cravath Swaine & Moore is advising MCI WorldCom, the US's second-largest communications company on its acquisition of SkyTel, the wireless communications company. MCI will pay $1.8 billion for the company. The purchase will be made in stock and includes assumption of debt. The two companies have had business arrangements with each other for some time, and MCI WorldCom is the largest reseller of SkyTel services.

  • Shearman & Sterling works on paper deal

    Shearman & Sterling is advising US holding company Georgia Pacific on its acquisition of North America's largest paper distributing and marketing company, Unisource.

  • McDermott Will handles RAG transaction

    McDermott Will & Emery is advising RAG International Mining on its acquisition of Cyprus Amax coal company. The deal is valued at $1.1 billion in cash and debt. Cyprus Amax Coal is one of the biggest coal mining companies in the US and has properties in Pennsylvania, Wyoming, Utah, Colorado and Illinois. RAG is a subsidiary of the German energy and technology company RAG Aktiengesellschaft.

  • Kramer Levin handles Tyco takeover

    New York firm Kramer, Levin, Naftalis & Frankel is advising Bermuda company Tyco on its acquisition of Raychem. Tyco is the world's biggest underwater communications firm, and Raychem designs, manufactures, and distributes electronic components. Tyco will pay $1.4billion in cash and will issue 16 million new shares based on the remainder of the Raychem shares.

  • Weil Gotshal advises on Hicks Muse/Hillsdown deal

    Weil Gotshal & Manges is advising Hicks Muse Tate & Furst on its £822 million ($1.3 billion)bid for UK foods comapny Hillsdown Holdings. Hillsdown's brands include Typhoo tea, Cadbury's biscuits and HP canned foods.

  • Wal-Mart looks to Ernst & Young

    Ernst & Young and Simmons & Simmons are advising Wal-Mart Stores Inc, the world's largest retailer, on its £6.7 billion (S10.8 billion) bid for UK supermarket group Asda.

  • Taxfax

    Charge of Deloitte brigade Clowning around at the CIOT Tax Litigator shifts to private firm Liu seduced by Sidley's charms KPMG recruits Brockway Smart moves for Arthur Andersen Sutherland Asbill expands in Washington

International Correspondents

International Correspondents