ITR Search | International Tax Review

ABA wants more IRS guidance on related-party guarantees

The Section of Taxation of the American Bar Association (ABA) has written to IRS Commissioner Doug Shulman with recommendations for guidance on the transfer pricing of related-party guarantees.

Matthew Gilleard, October 03 2012

Has PepsiCo’s US Tax Court win revealed “super factor” in deciding debt vs equity cases?

In the latest US court ruling in a debt-versus-equity case, the 100-page judgment in the litigation concerning soft drinks company PepsiCo could help indicate the “super factor” in characterising a structure.

Joe Dalton, October 03 2012

High Court sets November date for Fortescue Metals mining tax battle

Australian iron ore company Fortescue Metals was granted leave by the High Court yesterday, to clarify the case it wants to bring against the government over the Minerals Resource Rent Tax (MRRT).

Joe Dalton, October 03 2012

Commission refers UK to ECJ for failure to implement Marks & Spencer ruling

The European Commission is referring the UK to the European Court of Justice (ECJ), claiming its cross-border loss relief rules still infringe EU law, despite amendments made after the Marks & Spencer ruling.

Joe Dalton, October 03 2012

South Africa rejects taxpayer’s use of losses in Armgold mining case

The South African Supreme Court of Appeal rejected the taxpayer’s and South African Revenue Service’s (SARS) arguments in its Armgold judgment this week, where it addressed the deduction of mining capital expenditure for taxpayers operating multiple mines.

Joe Dalton, October 03 2012

UN tax committee publishes draft transfer pricing manual

The UN Committee of Experts on International Cooperation in Tax Matters will consider its draft Transfer Pricing Manual for Developing Countries at its eighth session in Geneva from October 15-19.

October 02 2012

Pace comes back to KPMG

KPMG in the US has boosted its economic and valuation services practice by hiring Marco Pace, previously vice president of international tax at Thomson Reuters. He will advise clients on operational transfer pricing and related tax services.

October 02 2012

What you have missed on ITR Premium

New Indian tax accounting standards; Netherland to abolish thin capitalisation; Malaysia moots corporate tax cut; Possibility of US carbon tax; Serbia changes VAT; GAP's Indian TP dispute; the future for TP disputes

October 02 2012

Outstanding firms unveiled at Americas Tax Awards

Hot on the heels of the presentation of the primetime Emmy awards earlier in the week, the seventh annual Americas Tax Awards ceremony took place in New York on September 27.

Ralph Cunningham, October 02 2012

Links found between US audit risk and extra tax receipts

The threat of being audited by the Internal Revenue Service in the US prompts poorly governed companies to be more scrupulous about their tax return filing and financial reporting, two new studies have found.

October 02 2012

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