Magazine
May 2002

Magazine Archive

Brown's budget incenses business community
KPMG loses tax partner to Baker McKenzie
Lovells penetrates key Dutch market
Allen & Overy launches German tax group
US takes credit for dubious haven 'success'
Singapore plans cuts to aid investment
UK rules on share option case
Why EMU means little to the US

The US has failed to recognize the European Union as a single economic entity for tax purposes. This raises a number of potential problems for US and EU companies. By Stephen E Fiamma and Dave Lewis of Allen & Overy's US Tax Group, London
Employee stock options and transfer pricing

Tax authorities in a number of countries are increasingly focusing on transfer pricing issues related to stock options. Ernst & Young transfer pricing and stock-based compensation professionals have collaborated to review the pitfalls and opportunities with particular reference to the UK, the US and Germany. By Gareth Green and Jeremy Glover in London and Stanley Veliotis in New York
Buying and selling in post-Budget UK

UK corporate tax reform and the changes brought about by last month’s Budget will have a major impact on M&A transactions. Gary Richards of Weil, Gotshal & Manges, London, outlines some of the key issues
Managing funds in China’s post-WTO environment

Excitement is mounting for foreign participation in China’s post-WTO fund management market. However, careful tax planning is essential. Matthew Wong of PricewaterhouseCoopers, Shanghai, reports
Canada cracks down on profit split

Canada’s revenue authorities are taking an aggressive stance on profit split methods – taxpayers use them at their peril. By Hendrik Swaneveld, Venkat Nagarajan and Martin Przysuski, BDO Dunwoody LLP, Toronto (Markham)
Corporate inversions come under US scrutiny

More and more US multinationals are performing corporate inversions to establish parent companies in tax havens and thus reduce the amount of US tax payable. However, as Keith Martin and Samuel R Kwon of Chadbourne & Parke LLP, Washington, warn, the days of the corporate inversion may well be numbered
How to tackle employee retirement plans

Covering foreign employees in US retirement plans is a complex area and mistakes can be costly. Robert H Masnik and Karen Field of KPMG’s Washington National Tax Compensation and Benefits practice discuss the issues
Netherlands rules on deductibility of interest by international groups

In the wake of a recent Supreme Court ruling, the reasonable taxation standard is clarified, and activities within the scope of the Irish IFSC regime are found to be comparable to activities within the scope of the Dutch GFC regime. By Daan de Bruin and Judy Chan Deloitte & Touche, International Tax Group, Netherlands
Understanding Belgium's participation exemption

In the second instalment of this two-part article, Jan Muyldermans, Kurt De Haen and Wim Eynatten of PricewaterhouseCoopers, Brussels, explain Belgium’s recently issued guidelines on participation exemption
Global transfer pricing developments

Influenced significantly by methods based on the OECD transfer pricing guidelines, many countries are adopting and supplementing transfer pricing rules to compete and protect their tax base. This column highlights major transfer pricing developments around the world during the past few months. By Bill Dodge and Giovanni DiCenso, Deloitte & Touche, Washington, DC
US gets down to business

Efforts are made to phase out the extraterritorial income exclusion regime, anti-inversion legislation is proposed, and broad business purpose/economic substance standards are set. By Hal Hicks, David Benson and Margaret O’Connor of Ernst & Young, Washington DC
Hong Kong offers electronic filing, while China survey reveals WTO optimism
Aid probes and German real seat doctrine
Athinaiki and the French précompte
Scope of subject-to-tax clauses in German tax treaties
Tax law changes
New rules affect Mexico's 2002 tax reform
Extension of UK tax credit for research and development
Deals
Oppenheimer hires Paris head of tax
Andersen carve-up continues