Magazine
October 2000

Magazine Archive

UK Revenue defeated on conversions

Four UK building societies that converted to banks in the late 1990s claimed tax deductions for the costs of converting. The Inland Revenue disputed this, but the Special Commissioners of Tax found in the building societies’ favour. Hartley Foster of Clifford Chance reports
Slaughter & May works on Abbey National’s Scottish Provident purchase
Lovells advises on technology deal
Time Warner Telecom turns to Paul, Weiss
Shearman & Sterling acts for Credit Suisse
McDermott Will restructures Daewoo
Freshfields advises on Kingfisher demerger
National Power turns to Linklaters
National Grid opts for PwC
Davis Polk advises in $1bn share issue
Cameron McKenna helps in Lloyds acquisition
Jones Day in $3 billion oil deal
Davis Polk assists Chase in JP Morgan acquisition
Herbert Smith defends LSE
Triple jump to Deloittes
Dewey Ballantine expands London office
Latham & Watkins gains tax partner
Third Gide partner defects to Freshfields
Lovells opens new offices in Italy
McDermotts gets an energy boost in New York
McCann FitzGerald poaches tax man from KPMG
UK APAs put to the test

Taxpayers are still testing the waters in the matter of how the UK Inland Revenue manages its advance pricing agreement process. Peter Nias of McDermott, Will & Emery, London describes the ins and outs of a recent case in which he was involved
Marathon case could end in defeat for UK Revenue

The advocate general of the ECJ has opined against ACT payments and in favour of Hoechst and Metallgesellschaft under the freedom of establishment principle
France’s largest tax cut for 50 years
Fuel frenzy hits Europe
Hewlett-Packard in talks to buy PwC Consulting
Arthur Andersen report helps level the lobbying playing field
Japan plans tax reform
Linklaters improves client relationships
California plans sales tax on online purchases

In a surprise move, California proposes an online sales tax, but the odds are against it becoming law
Treaties fail to protect capital gains

Australia introduced capital gains tax in 1985, but the question of how its provisions interact with those in tax treaties has never been put to the test. Ian Dinnison, KPMG Melbourne looks at a new draft ruling from the Australian Taxation Office
Rich EU rewards the wary

EU member states offer a rich investment environment for US multinationals. But, together with lucrative rewards, come the multiple layers of EU taxes, which require careful, focused planning. By Rolf Eggert and Robert van Brederode, KPMG’s Tax Centers of Excellence
Brazil broadens its tax base

The Brazilian tax authorities have completed their annual round of corporate tax changes. Abel Simão Amaro and Lionel Pimentel Nobre, of Amaro, Stuber e Advogados Associados, Rio de Janeiro, look in detail at the key issues facing foreign investors
Coping with the QI burden: part I

In the first of two articles, Marnin Michaels, David Balaban, Peter Connors, Philip Marcovici, and Thomas O’Donnell of Baker & McKenzie review the stringent requirements of the new qualified intermediary regime in the US and suggest ways to address them
Russia reverses non-disclosure

Cautious optimism for foreign investors in Russia follows radical efforts by the government to level the playing field for business. In the second of two articles, Robert Fort of Deloitte & Touche, Moscow reports on Russia’s most recent changes
Are you being served?

This year’s IFA Congress, held at Munich’s Kulturzentrum am Gasteig from September 3 to 8, drew 1,500 professionals. But despite the international flavour in terms of both attendees and subject matter, did it really succeed in dishing up what delegates were looking for?
Thailand clears up VAT assessment

Since Thailand introduced VAT in 1992, the Revenue Department has issued numerous individual rulings on tricky areas. Self-assessment has been a particular sticking point. By Kitipong Urapeepatanapong and Chaiyong Ngampravatdee, Baker & McKenzie, Bangkok
New administrative guidelines
Tax reform, 2000: branches and partnerships versus subsidiaries as inbound investment vehicles
Proposed taxation of dividends
Discrimination against foreign companies
Customs issues valuation ruling based on IRS advance pricing agreements
Deborah Lange

Deborah Lange Senior vice-president, tax, Oracle Corporation: Deborah Lange was last month promoted to senior vice-president of tax at the US’ Oracle Corporation. She explains to Sharon Cunningham why, after 13 years with the leading technology company, her enthusiasm for the job has not wavered
Allen & Overy the choice of Rémy Cointreau
Citigroup opts for Skadden Arps