World's leading tax advisers: Part 3 - North America: North America bunkers down Sed Crest speaks to the leading tax advisers in North America at a time when creative tax advice is under increasing threat from the media, lawmakers and the IRS
Corporate inversions in the spotlight A report by the US Treasury Department proposes attacking corporate inversions through stricter enforcement of the earnings stripping rules. By Isaac Grossman and Victoria Litz, Clifford Chance Rogers & Wells LLP, New York
European VAT system fights for survival With VAT fraud in the EU taking on forms never envisaged by the original legislators, concerted action to tackle the issue is urgently required. By Stephen Dale and Hélène Percie du Sert, Landwell – the correspondent law firm of PricewaterhouseCoopers, Paris, and Christine Sonneleitner, PricewaterhouseCoopers, Vienna
Mexican transfer pricing under the microscope Mexico's transfer pricing reforms are somewhat vague but could increase the overall tax bruden. By Jorge Narvaez-Hasfura and Eric Torrey, Baker & McKenzie, Mexico City
Inside Washington The Supreme Court agrees to review the Boeing decision, a new information agreement is signed with Netherlands Antilles, and the IRS denies APAs to check-the-box taxpayers. By Hal Hicks, David Benson and Peg O'Conner, Ernst & Young, Washington
How to comply with India's transfer pricing rules India's Finance Act 2001 introduced transfer pricing provisions. Tax payers are now gaining their first experiences of how to comply with the new rules. By Samir S Mogul, S I Mogul & Co, Mumbai
Inland Revenue overruled by legal privilege According to the recent ruling in the Morgan Grenfell case, the UK revenue authorities do not have the power to access legally privileged documents. Mark Kingstone and Dominic Winter, Linklaters, London report on the decision
Getting the most out of Japanese restructuring Investors in Japan have a variety of new rules at their disposal for setting up share-for-share exchanges and corporate restructuring. Take full advantage, urge Todd M Landau and Shinji Ishiguro of PricewaterhouseCoopers, New York and Tokyo
Final regulations for domestic reverse hybrids in the US New regulations from the US Treasury recharacterize non-deductible dividend payments to foreign parents. By Mike Danilack, Diane Renfroe and Lisa Askenazy Felix, Deloitte & Touche, Washington, DC
Knowledge intangibles -- leveraging the tax advantages Tax planners should use the global knowledge contained in an enterprise -- perhaps through the creation of global knowledge holding companies -- to yield significant tax savings. By Marcus Collardin and Alexander Vögele, KPMG, Frankfurt
EU gets serious about tax harmonization As the EU gets serious about tax harmonization, investors need to give serious consideration to alternative tax scenarios. By S Alan Hamburger, Morgan Lewis & Bockius, Brussels
ECJ postpones ruling on Austrian dividends received tax; ECJ hears case on German thin capitalization rules