Magazine
March 1998

Magazine Archive

Ernst & Young and KPMG merger crumbles
United Kingdom
United States
SmithKline Beecham turns to Linklaters and Shearman & Sterling
Skadden, Arps helps Compaq in bid for Digital Equipment
Canadian National Railways turns to US firm
Chadbourne & Parke works with Tommy Hilfiger
BOC turns to Shearman & Sterling
Osler, Hoskin & Harcourt consulted on Canadian bank merger
Linklaters advises on £8 billion Eurotunnel debt restructuring
Omnicom looks to Herbert Smith
Davis Polk advises on Thermadyne acquisition
Coopers & Lybrand/Price Waterhouse joint opinion
Kerry Group seeks advice from Deloitte & Touche
Wachtell, Lipton, Rosen & Katz assists Raytheon
Freshfields advise on Scottish Equitable disposal
Slaughter & May helps dispose of Spillers
Cravath advises on Homestake acquisition
Europe maps out tax boundaries of Emu
News Corporation’s tax bill hits the headlines
Deloitte Touche Tohmatsu releases tax results
For the library
News in brief
Taxfax
EU steers UK group relief rules

ICI has taken its case for consortium relief to the European Court of Justice. The Advocate-General’s opinion may not satisfy ICI, but it does imply the liberalization of consortium relief for EU businesses. By Murray Clayson of Freshfields, London
China: layered incentives draw investors

China offers foreign investors a host of tax incentives, many of which can run simultaneously. Kenneth Leung of Clifford Chance, Hong Kong looks at the opportunities, the criteria for qualification and the interaction of the available incentives
Hybrid branches face stern test

The US Internal Revenue Service has signalled its intention to limit the tax advantages available to some hybrid branches. Joseph DeCarlo of Price Waterhouse LLP, and Alan Granwell and Dirk Suringa of Ivins, Phillips & Barker, Washington DC report
Holding competition hots up

A comparative approach is adopted in this assessment of Italy’s realistic potential as a holding company location. By Piergiorgio Valente and Marco Magenta, Studio Associato Legale Tributario (associated with Ernst & Young International), Milan
Striking a good deal in Japan

Japan now offers foreign investors a warm welcome, and a range of acquisition opportunities. Dean Yoost and Todd Landau of Coopers & Lybrand in Tokyo and New York present a tax guide to structuring acquisitions in Japan
Germany: reform by example

Hans-Peter Niedrig and Axel Schiller of KPMG Düsseldorf use practical examples to illustrate the real affects of changes to German tax law, including the taxation of reorganization profits, accruals for anticipated losses, and loss deductions for shell purchases
US position raises new questions

A new provision and temporary regulations should simplify the complex issues relating to passive foreign investment companies. Unfortunately, the rules inadequately address key issues. By Dale Collinson and Patrick Carmody of Willkie, Farr & Gallagher in New York
Expatriate taxation in Europe Survey Part three: The discreet charms of expat tax

Italy, Spain, Sweden and Switzerland are not celebrated expatriate tax locations, but as the third and final part of this survey shows, they offer some hidden attractions, some planning opportunities, and present some pitfalls to watch out for
The Taxation of Intangibles (Special supplement): Japan

A special report prepared by Jonathan Stuart-Smith and Tomohiko Kaneko of Deloitte Touche Tohmatsu, Tokyo
The Taxation of Intangibles (Special supplement): United Kingdom

A special report prepared by Christopher Fitzgibbon of Deloitte & Touche, London
The Taxation of Intangibles (Special supplement): United States

A special report prepared by Michael Knee, Washington and Robert Misey, Nashville Deloitte & Touche LLP
Canada
Finland
France
Germany
Norway
Russia
Spain