May 2007

Main

Grasping for air

Interest deduction removal causes controversy in Canada

Transfer tax on the sale of Spanish real estate companies

Advance rulings on the group contribution system

Treatment of M&A deals with share-swaps and preference share redemption

UK Budget round-up

Time for changes to the taxation of international and M&A transactions

Making a section 338 election for the purchase of stock of a foreign eligible entity that has been irrelevant for US tax purposes

IRS addresses commensurate with income provision

Barclays resists benefits of going Dutch

Who's worked on the biggest deals

Flourishing tax market makes case for new partners

IRS looks for new commissioner

Editorial

Beware the rush to tax

Danish revisions soften blow to business

Offshore amnesty announced in the UK

Paulson details strategy to reduce the tax gap

New faces join Transfer Pricing Forum

Officials differ on international cooperation

Businesses take territory seriously

Time to confess

Baltics grapple with VAT

A definite resemblance

On top of the rules

General resolution 2228 brings new domestic regulations to define eligibility for treaty benefits

International transfer pricing taxation ruling: Division 13 adjustments

Deduction for patent income: a new measure in favour of innovation

New central bank reporting requirements for Brazilian-owned foreign assets introduced by government

The 2007 Federal Budget

Central American update

Accelerated depreciation

The new PRC Enterprise Income Tax Law and restructuring investments in China

Tax authorities issue guidance on tightened treaty shopping rules

No requirement to have a Permanent Establishment for taxability of income in the year of receipt

The tax consequences of converting to a different corporate entity

Clarification on Maquiladora permanent establishment issues

Rules on Polish VAT refunds for foreign entrepreneurs liberalised

Budget overview

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

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