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  • How to manage risks in transfer pricing controversy
    Tax authorities around the world are stepping up their enforcement of transfer pricing rules. It means taxpayers must prepare adequately to address any of their concerns, say Todd Wolosoff and Larry Powell of Deloitte
    December 01 2010
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    Industry responds to OECD on withholding tax
    In early 2010 the OECD released a discussion draft implementation package that provides for a streamlined withholding tax relief process. Paul Radcliffe of Citi looks at the industry responses to the proposals and explains why a consistent international approach to modernising rules in this area is vital.
    December 01 2010
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    Poll reveals challenges across Latin America
    Executives responsible for the Latin America region often claim they have the most difficult job in the tax department. As Elizabeth Bearese discovers the results of International Tax Review’s Latin America Client Services Poll seem to justify the claim.
    December 01 2010
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    Why tax authorities need to respect client privilege
    Jason Collins of McGrigors and Don Korb of Sullivan & Cromwell explain why tax authorities need to respect client privilege and show how the US and UK handle confidential tax matters.
    December 01 2010
  • McGladrey grows in Washington
    Robert Adams has joined RSM McGladrey as a managing director for the IRS practice and procedure team in Washington DC .
    December 01 2010
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    Italy explains treatment of debt into equity investments
    With the release of Circular 42/E, the Italian tax administration provided clarification regarding the methods of application of article 113 of the Italian Tax Code. Fulvia Astolfi and Antonella Prencipe of Hogan Lovells explain.
    December 01 2010
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    Changes to the IOF rates
    Nélio Weiss Philippe Jeffrey Two decrees published on October 5 and 18 2010, introduced changes to the tax on financial transactions (IOF). They have increased the rate applicable to inflow currency transactions for investments in the Brazilian financial and capital markets to 4% for operations contracted from October 5 to October 18 2010, and to 6% for operations contracted on or after October 19 2010.
    December 01 2010
  • Canadian companies should brace for increased audits
    Canadian multinationals can expect to face more audits in the coming years as the Canada Revenue Agency (CRA) focuses on enforcement activity.
    December 01 2010
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    The blurring lines in tax planning
    A company’s obligation to its shareholders is to minimise tax and a government’s, to its people, is to close the tax gap. Where does that leave tax planning? Sophie Ashley talks to government officials, taxpayers and advisers to uncover where the confusion lies in a changing environment.
    December 01 2010
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    Technology targets tax risk reduction
    Bob Norton, chief income tax officer at Vertex, argues that taxpayers have to realise that enterprise technology will be a necessity if they want to cut the risk of tax exposure.
    December 01 2010
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