Authorities get information exchange warning as Cayman taxpayers get ATO request quashed Tax authorities need to follow information exchange protocol more carefully or risk having requests blocked, after the Australian Taxation Office (ATO) sought financial details about two Cayman Islands firms but... By Joe Dalton October 03 2013
Grattan’s UK tribunal defeat does not rule out fiscal neutrality arguments Clothing retailer Grattan’s UK First-tier Tax Tribunal (FTT) defeat showed that fiscal neutrality is an aid to interpreting VAT directives, not a rule of substantive law. By Joe Dalton October 02 2013
Deals of the month See who has done the tax work on this month's biggest deals By Joe Dalton September 30 2013
Unlocking MAP disputes: Is mediation the key? Item 14 of the OECD's Action Plan on base erosion and profit shifting (BEPS) aims to devise solutions to obstacles preventing countries from resolving cross-border disputes under the mutual agreement... By Joe Dalton September 30 2013
Has US Tax Court’s concession to BNY Mellon opened new chapter in STARS cases? The Bank of New York Mellon’s (BNY Mellon) US Tax Court victory on Monday could see a new wave of taxpayer claims in structured trust advantaged repackaged securities (STARS) cases. By Joe Dalton September 25 2013
HMRC upping ADR capacity for large taxpayers after successful pilot HM Revenue & Customs (HMRC) has published an evaluation of its pilot on alternative dispute resolution (ADR) for large and complex tax cases, and says it will up its mediation... By Joe Dalton September 25 2013
Irish Revenue Commissioners reviewing 12 multinationals’ TP compliance After the European Commission’s announcement it is investigating Ireland, Luxembourg and the Netherlands in relation to preferential tax rulings, the Irish Revenue Commissioners say they are reviewing the transfer pricing... By Joe Dalton September 25 2013
BB&T loses STARS case but ruling clouds legitimate tax planning rights in US US bank BB&T is considering appealing Friday’s Court of Federal Claims defeat, despite the case judge describing its tax credit generator scheme with Barclays as an economically meaningless tax shelter. By Joe Dalton September 25 2013
BMC Software loses fight over repatriation rate in US Tax Court US specialist software provider BMC Software lost its case against the Internal Revenue Service (IRS) over tax due on income repatriated between 2005 and 2006 in the Tax Court on... By Joe Dalton September 19 2013
