India’s Income Tax Appellate Tribunal (ITAT), Kolkata bench, ruled that distributing dividends immediately before a share sale to reduce capital gains tax liability is acceptable tax planning. But, changes to India’s capital gains tax regime for non-residents mean the scheme will only benefit some taxpayers.
A case about the misuse of tax information exchanged between the US and Japan, which appeared before the US Court of Appeals for the Ninth Circuit recently, raises serious questions about what remedies taxpayers will have if their information is misused under FATCA.
D’Ascenzo hopes other taxpayers will follow Alcoa’s lead and enter more comprehensive ACAs Alcoa, the multinational aluminium producer, recently signed an Annual Compliance Arrangement (ACA) that was described by Australian Tax Commissioner Michael D'Ascenzo as "historic" because of its comprehensive nature. International Tax Review looks at whether such a broad ACA is best for taxpayers. The Australian Taxation Office (ATO) introduced ACAs in 2008 as an administrative arrangement defining and governing the compliance relationship between the ATO and taxpayers.
Multinationals can raise capital in Australia and pay distributions to Australian resident investors out of foreign source income with imputation benefits attached, after the High Court’s ruling in a general anti-avoidance rule (GAAR) case involving the Commonwealth Bank of Australia (CBA).
Canadian taxpayers whose business is acquiring companies may still be able to file break fees received under a pre-acquisition agreement on capital account, despite the Federal Court of Appeal’s (FCA) ruling in the Morguard Corporation case last week, according to an adviser.
