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  • Searching for the virtual tax planner

    Tax directors are drowning in a sea of information. But as books give way to disks and CD-Roms, Oliver Ralph asks software users and suppliers how electronic information can help tax professionals and how much value these products really represent


  • US classifies software deals

    After two years of discussion, the IRS has finalized the rules covering the classification of software transactions. Alan Levenson and Alan Shapiro, Deloitte and Touche LLP, San Jose & Washington DC, examine the consequences for software developers around the world

  • 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.

  • India adds to foreign tax burden

    A recent ruling means that non-resident companies with a permanent establishment in India must now comply with the country’s minimum alternative tax policy. Jignesh R Shah, Price Waterhouse & Co, Mumbai analyzes the case and its implications

  • US courts get tough on schemes

    Taxpayers who believe that their transactions are too complex for the revenue authorities to sort out should pay very close attention to recent IRS victories in the US courts. By Keith Martin, Chadbourne & Parke, Washington DC

  • Blueprint for UK APAs

    Self-assessment for transfer pricing exposes taxpayers to several potential risks. In this context an effective APA system is vital. Robert Cole, Alston & Bird, Washington DC and Michael McGowan of Allen & Overy, London outline their recommendations.

  • US hybrids: the changing landscape

    The second of two articles on the US check-the-box regulations examines the opportunities for investing from the US and the impact of recent changes. By Shawn Carson (BDO Seidman, New York), Allan Cinnamon and Zigurds Kronbergs (BDO Stoy Hayward, London)

  • IFA: more questions than answers

    The 52nd IFA Congress, held in October this year, sported a new style. But was the substance and quality of debate enhanced? Phillippa Cannon sifts through the discussions to identify key questions and, in some places, even conclusions

  • Accounting for Colombian inflation

    Tax planners ignore inflationary adjustments at their peril. Mario Andrade and Mario A de Castro, Deloitte & Touche Consultants, Bogota consider the accounting requirements for companies created by Colombia’s high rate of inflation

  • GAAR survey: Part One, Australia: Uncertainty rules in Australia

    In part one of International Tax Review’s GAAR survey, Bill Orow of KPMG in Melbourne examines the Australian rules. Recent changes have done little to reassure worried tax directors and the introduction of a smell test has left a bitter aftertaste

  • GAAR survey: Part One, Sweden: Taxpayers left guessing in Sweden

    Sweden has attempted several versions of a GAAR. However, the latest version still leaves taxpayers uncertain that it will be applied to their transactions. By Brita Munck-Persson and Thomas Lakhall, Mannheimer Swartling Advokatbyrå, Stockholm

  • Gaining credit in Germany

    Though contrary to European law, foreign shareholders in Germany are prevented from claiming a tax credit available to German nationals. But, as Hans-Jörg Fischer of Clifford Chance, Frankfurt, explains, the courts may well assist foreigners to claim their full entitlement

  • Japan opens up debt securities

    Changes to Japan’s debt securities regime have cleared the way for withholding tax exemption. Yusaku Ono of Hamada & Matsumoto, Tokyo advises on how non-residents and non-Japanese corporations can make the most of the new system

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International Correspondents

International Correspondents