Search results for

Heike Weber Two lawyers from Continental Europe have made the step-up after Allen & Overy's annual announcement of new partners.

The English Court of Appeal has accepted a lower court's reasoning that claims for compound interest in European tax cases are time-barred. But the judgment has left many areas still undecided, believes Savina Kanagasabay of Dorsey & Whitney

Phani Tillirou Cyprus is an established, reputable international financial business centre with an extensive tax incentives regime whereby global investors can rely on and ultimately benefit from. The favourable geographic location of Cyprus, in line with its most favourable tax and legal regime, its EU membership as well as the wide network of double tax treaties concluded make Cyprus a preferred jurisdiction for hosting the activities of International Collective Investment Schemes (ICIS).

Bob van der Made On October 20 2009, Jose Manuel Barroso the president of the European Commission announced he had tasked Mario Monti, president of Bocconi University and EU commissioner for the internal market, financial services and tax policy from 1995 to 1999) and for competition from 1999 to 2004), with the mission of "preparing a report containing options and recommendations for an initiative to re-launch Europe's Single Market as a key strategic objective of the new Commission". Monti was to conduct this mission under his personal responsibility, but was able to call on the commission's expertise and support. He has since held consultations with the European Parliament, several EU commissioners, member states and other stakeholders.

Nélio Weiss Philippe Jeffrey The Administrative Tax Appeals Council (CARF) recently announced the legal grounds used in a controversial decision issued in 2009 in connection with the Brazilian controlled foreign corporation (CFC) rules.

By David Stevenson

Edward Tanenbaum Tola Ozim On February 26 2010, the Financial Crimes Enforcement Network (FinCEN) of the US Treasury Department issued a notice of proposed rulemaking proposing to amend the Bank Secrecy Act (BSA) implementing regulations regarding the Report of Foreign Bank and Financial Accounts (FBAR). On the same date, the Treasury and the Internal Revenue Service (IRS) issued long-awaited additional guidance to FBAR filers. Notice 2010-23, 2010-11 IRB was issued extending the filing deadline for certain FBAR filers until June 30 2011. The Notice also provided some clarity with respect to the FBAR filing obligations pertaining to commingled funds. In addition, Announcement 2010-16, 2010-11 IRB was issued continuing the suspension of FBAR filing requirements for persons who are not US citizens, residents or domestic entities.

The Portuguese Budget Law for 2010 was approved by the Portuguese parliament on March 15 2010. Although the final text of the law is not yet available, the proposals initially included in the Budget Bill proposal were accepted together with relevant final amendments. These last minute inclusions cover the reduction of the loss carry forward period from 6 years to 4 years, amendments to the property tax exemption available for certain real estate investment funds, and adjustments to tax amnesty for undeclared funds held abroad.

Hatasakdi na Pombejra In general, the franchise agreement is an agreement made between the franchisor and franchisee for the right to use the franchisor's brand know-how, including relevant services. For this purpose, the franchisee agrees to pay the franchisor in a form of franchise fee, royalty fee, marketing and advertisement service fee and other service fees to the franchisor.

Passarella Abogados is a new firm in Buenos Aires that has been set up by Leandro Passarella, a well-known tax lawyer. He advises corporations on the Argentine tax implications of M&A transactions, reorganisations and leveraged buy-outs, and the tax-efficient structuring of businesses and start-ups in general. He also designs tax structures for regional transactions and operations. His practice includes the legal assistance to clients in tax audits and litigation.