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Bryan Bailey Ilan Braude On June 23 2011 the Supreme Court of Canada granted the taxpayer's application for leave to appeal the decision of the Federal Court of Appeal (FCA) in St Michael Trust Corp v The Queen (commonly referred to as Garron). The FCA upheld the decision of the Tax Court of Canada that certain offshore trusts were taxable in Canada on the basis that they were resident in Canada for Canadian tax purposes.

Sead Dado Salkovic Montenegro is showing great interests in all aspects of sport. Many professional athletes perform their activities according to the regulations specified by the general act of sporting organisation. The question is, what about the VAT subsequences of these services?

Igor Roman of Deloitte Poland takes a look at some of the issues and explores some options for resolving the critical challenges facing companies in respect of tax reporting.

Thomas Humphreys, Remmelt Reigersman and Jared Goldberger of Morrison & Foerster run through the latest developments for FATCA in the US and explain that foreign financial institutions and withholding agents should benefit from additional time to comply with the rules.

David Cuéllar Claudia Solano The Flat Tax Law was published on October 1 2007, entering into force as from January 1 2008. As part of the transitory provisions of the Flat Tax Law, article 19 establishes that the Mexican tax authorities shall conduct a study showing a comprehensive diagnostic regarding the convenience of repealing certain chapters of the Mexican Income Tax Law (regarding the tax regime applicable to the entities and individuals), to be regulated solely by the Flat Tax Law.

Slobodan Mihajlovic Sead Dado Salkovic Aiming to improve tax legislation, the government of Republika Srpska (RS) is adopting a package of tax solutions needed for more "rational and competitive" tax system in this Bosnian entity.

Gary Thomas As part of its 2011 tax reforms which were belatedly passed in late June, Japan has adopted the most appropriate method rule for selecting a transfer pricing method. According to the new rule, the arm's-length price is the amount which is computed in accordance with the most appropriate method, taking into account the contents of the transaction, the functions performed by the parties and other circumstances. This change will go into effect for tax years commencing on or after October 1 2011.

Paul Chambers Samantha Nonnenkamp The Luxembourg government recently adopted a draft law that amends, as of January 1 2012, the regime applicable to SPFs (private wealth management companies), as defined by the law of May 11 2007 (SPF Law). SPFs are investment vehicles dedicated to private investors which benefit, under certain conditions, from an exemption from corporate income tax (CIT) and municipal business tax (MBT) on profits and capital gains as well as from net wealth tax (NWT). In the following developments, we explain why the SPF regime had to be amended and why this amendment will make SPFs even more attractive than before.

Simeon Grigorov More and more Greek and Romanian companies are registering in Bulgaria, one of the three countries with the lowest corporate taxes in the EU. According to the NRA (National Revenue Agency) the number of companies with Greek capital, that declared corporate income tax in Bulgaria for 2010 is 2074. This is 183% more than in 2006.

Ian Farmer The much anticipated exposure draft (ED) legislation for the proposed minerals resource rent tax (MRRT) was released on June 10 2011, accompanied by detailed explanatory material. This is a significant step towards the implementation of the proposed MRRT as announced by the government on July 2 2010.