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Canada: Canadian Supreme Court confirms GAAR test

On December 16, 2011, the Supreme Court of Canada released Copthorne Holdings Ltd. v. Canada (2011 SCC 63), its fourth decision on the general anti-avoidance rule (GAAR). The court unanimously dismissed the taxpayer's appeal, upholding the two lower courts.

February 01 2012

Sullivan & Worcester promotes one to partnership

David Kaplan has become a partner of Sullivan & Worcester in Boston. He advises on the structuring of M&A and real estate transactions, including those relating to real estate investment trusts (REIT), as well as international tax planning for multinational clients and other tax planning for business entities.

February 01 2012

French FTT will only benefit UK, says Financial Secretary

Banks will leave France and relocate their financial transaction branches to the UK and other jurisdictions if President Nicolas Sarkozy goes ahead with the financial transactions tax (FTT), according to UK Financial Secretary to the Treasury Mark Hoban.

Joe Dalton, February 01 2012

Spain: Supreme Court provides guidance on thin capitalisation rules

Traditionally, the application of thin capitalisation rules has triggered a number of questions which have been extensively debated by tax commentators. Some of them have been clarified by the Spanish courts or the Directorate-General of Taxes in various rulings, but some others have remained open to discussion.

February 01 2012

Indonesia: Income tax treatment of shariah-based banking and financial Institutions

Suryohadi, PB Taxand Like in Malaysia and in many European countries, many private conventional banks and financial institutions in Indonesia have opened a business unit based on the shariah law (Islamic law). This trend to open shariah-related business activities is taking place to serve the increasing number of customers interested in the services of Islamic banking and financial institutions.

February 01 2012

Cyprus: New austerity measures and tax implications

Georgia Papa, Eurofast Taxand On December 14 2011, the parliament passed new laws which include new austerity measures that will allow Cyprus to financially recover and respond to the eurozone crisis.

February 01 2012

Luxembourg: Russia and Luxembourg amend double tax treaty

Paul Chambers

February 01 2012

The fine line between planning and avoidance

Leon Kwong Wing of KhattarWong-Taxand explains how a recent dispute from Singapore sheds light on the debate of a taxpayer’s freedom to legally arrange his affairs in such a manner that maximises his tax benefits against the natural desire of the state to collect the revenue it believes it should.

February 01 2012

Australia: Government winds back tax consolidation opportunities

Ian Farmer, PwC The Australian government has announced significant changes to the way the tax consolidation rules work for company groups. The latest measures operate to wind back the rights to future income (RTFI) and residual asset tax cost setting rules introduced by the same government only 18 months ago.

February 01 2012

US revenue’s increased focus on cross-border trade

As part of a continuing worldwide trend, the US Internal Revenue Service (IRS) is ramping up its efforts to deal with the international tax issues that arise as a result of increased cross-border trade. In the last year, the IRS has realigned its resources, focused attention on strategic issues, and begun to reshape its international tax administration. Barry Shott, Richard Barrett, and Jana Lessne, of PwC US, examine the implications of the IRS competent authority changes.

February 01 2012

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